Tribunal has to deal with factual findings of AO & give reasons for its conclusion

CIT vs. Promain Ltd (Delhi High Court)

Pursuant to a search u/s 132, the AO passed a block assessment order u/s 158BC. The Tribunal allowed the assessee’s appeal on the ground that (i) the search warrant did not mention the assessee’s name and (ii) the assessment was not based on material found during the search. The department filed an appeal claiming that (a) the search warrant & panchnama did refer to the assessee’s name and (b) the detailed assessment order exposing the assessee’s modus operandi had not been dealt by the Tribunal. HELD by the High Court allowing the appeal: