Reasoned disposal of objections in assessment proceedings required; cursory rejection and failure to address assessee's objections led to quashing and remand.

Quasi-judicial assessment orders must deal with each objection separately and give reasons, especially where the assessee contests reliance on seized material and the proposed tax quantum. A cursory rejection of objections deprives the assessee of fair procedure and prevents appellate scrutiny. Because the assessing authority, appellate authority and Tribunal repeated the same defect without independently examining the objections or the basis of the assessment, the Tribunal's order was quashed and the matter remitted for fresh consideration and consequential orders.

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Issues: Whether the assessment and appellate orders were vitiated for failure to deal with the assessee's objections and for breach of fair procedure, warranting quashing and remand.

Analysis: The assessee had filed objections to the proposed assessment, including objections to reliance on seized materials and to the quantum of tax proposed. The assessing authority rejected the objections in a cursory manner without separately considering them or giving reasons. The appellate authority and the Tribunal repeated the same defect and did not independently examine the objections or the basis of the assessment. A quasi-judicial authority must meet objections seriatim and give reasons so that the affected party knows why its contentions were rejected and the appellate forums can test the correctness of the decision.

Conclusion: The Tribunal's order was quashed and the matter was remitted to the Tribunal for fresh consideration of the assessee's objections and for appropriate consequential orders.

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