In thepresentcase, the EDC charges, on the aforesaid rationality, cannot be subjected to s. 194-I of the Act. Moreover, if such was the understanding of the Revenue, it should have been well founded and disclosed in the reasons recorder by the AO. Deduction at source is dealt under Chapter XVII of the IT Act. The provisions enumerated thereunder, stipulate requirement of deduction of tax at source. Revenue is unable to point out any specific provision which deals with EDC payment except for alluding to s. 194-I. We need not delve into this question any further as we do not find this to be a ground spelt out in the reasons for reopening the assessment under s. 147 of the Act. The statutory orders containing reasons have to be Judged on the basis of what is apparent and not what is explained later. Revenue cannot be permitted to improve the same by offering better Explanation during the course of the proceedings. On this issue we would like to refer the view of the Supreme Court in Mohinder Singh Gill & Anr. vs. Chief Election CIT & Ors. (1978) 1 SCC 405 where it has been held "The second equally relevant matter is that when a statutory functionary makes an order based on certain grounds, its validity must be Judged by the reasons so mentioned and cannot be supplemented by fresh reasons in the shape of affidavit or otherwise...".