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Section 254 of the Income-tax Act, 1961 - Appellate Tribunal - Order of Where Tribunal while dismissing appeal of revenue neither discussed all issues nor met reasoning given by assessing authority and appellate authority for coming to its conclusion, matter needed reconsideration by Tribunal On the basis of documents seized during search and seizure operation, an addition was made to the assessee's income. Pursuant to remand by the Commissioner (Appeals) the Assessing Officer passed a fresh order of assessment which was again set aside by the Commissioner (Appeals) observing that specific directions given to the Assessing Officer were not followed. Against the aforesaid order of the Commissioner (Appeals), the revenue went in appeal before the Tribunal which was dismissed by the impugned order. Held that from a perusal of the assessment order as also the order passed in appeal, it was apparent that the authorities had considered the facts of the case in detail and given reasons for arriving at the conclusion. The Commissioner (Appeals) had taken up all the issues separately and recorded findings on those issues. Curiously enough, the Tribunal while dismissing appeal of revenue neither discussed all the issues nor met the reasoning given by the assessing authority and the appellate authority for coming to its conclusion. Hence the matter needed reconsideration by the Tribunal. Accordingly the order of the Tribunal was to be set aside and the matter remanded to the Tribunal for deciding the appeal afresh by passing reasoned order after meeting the reasoning given by the assessing authority and the appellate authority. JUDGMENT M.Y. Eqbal, J.-This appeal under section 260A of the Income-tax Act, 1961, by the Revenue is directed against the order dated December 13, 2006, passed by the Income-tax Appellate Tribunal in I.T. (SS) No. 26/Pat/ 2006 for the assessment year, block period April 1, 1987, to October 21, 1997, whereby the appeal was allowed and the order passed by the Tribunal is set aside. It appears that a search and seizure was carried out under the provisions of section 131(1) of the Income-tax Act, 1961, in the premises of the respondent-assessee and…

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