Allowing the appeal of the revenue the Court held that the the Tribunal had merely recorded its conclusion and had not assigned any reasons in support of the conclusion. The Tribunal was directed to decide the claim of the assessee under section 40(a)(ia) of the Act afresh on the basis of the material available on record and on the basis of the reasoning assigned by the Assessing Officer as well as Commissioner (Appeals)]. The Court also observed that  It is well settled in law that even a quasi-judicial authority is required to assign reasons in support of its order. ( AY. 2008-09)