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Section 255 of the Income-tax Act, 1961- Appellate Tribunal - Procedure of - Whether if a detailed reasoned order is made by Appellate Officer and the Tribunal is in agreement therewith, then one may say that no detailed discussions are required but, when Tribunal is reversing order made by Appellate Officer, then detailed reasons are required to be given, particularly when decision of Tribunal is considered to be final on facts - Held, yes C.S. Aggarwal and Prakash Jha for the Appellant. R.D. Jolly for the Respondent. JUDGMENT B.C. Patel, CJ. - This appeal is filed under section 260A(1) of the Income-tax Act, 1961 (hereinafter referred to as the Act) against the order dated 23rd August, 2002 passed by the Income Tax Appellate Tribunal, Delhi Bench (hereinafter referred to as the Tribunal) in ITA No. 6331/Del./96 for assessment year 1993-94. 2. The questions framed by the court are as under:- "1. Whether there was any material before the Tribunal to reverse the decision of the CIT (Appeals) and hold that the assessee had suppressed its production of tin containers? 2. Whether the Tribunal was correct in law and/or facts in sustaining an addition of Rs. 1,74,58,165 representing alleged unaccounted sales?" 3. Answer to question No. 2 would be dependent on the answer to question No. 1. 4. The order made by the Commissioner of Income-tax (Appeals) which is produced at Annexure 4 in appeal No. 8/96-97 decided on 30-9-1996 is in detail. We have also perused the order made by the Tribunal wherein the Tribunal, in para 13, while reversing the order made by the CIT (Appeals), observed as under:- "13. We have examined the rival submissions. The Assessing Officer has methodically pointed out flows in the assessee's accounts as a result of the search in which production records were seized. In our opinion, the assessee has not been able to answer satisfactorily to any of the queries raised by the Assessing Officer. We are, therefore, in agreement with the Assessing Officer that…

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