Reasoned quasi-judicial orders are mandatory where constitutional tax protection is raised; cryptic rejection cannot stand.

Quasi-judicial revision under section 25 required the revisional authority to consider the factual and legal contentions and give reasons for its conclusion, especially where the challenge concerned the constitutional protection against taxation under Article 286(2). A bare statement that there was no reason to interfere was insufficient because it did not show application of mind to the controversy or enable effective review. The orders of the Board of Revenue were therefore quashed and the matter was remitted for fresh determination after hearing the petitioner.

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Issues: Whether the revisional authority's cryptic rejection of the revision petitions, without showing application of mind to the facts and law, could stand when the challenge involved the applicability of Article 286(2) of the Constitution.

Analysis: The revisional authority was exercising quasi-judicial jurisdiction under section 25 of the Madras Sales of Motor Spirit Taxation Act, 1939, and was therefore required to consider the factual and legal contentions and indicate the reasons for its conclusion. A bare statement that there was no reason to interfere did not disclose that the authority had examined the point raised or applied its mind to the controversy. In a matter turning on constitutional protection against taxation, a reasoned order was necessary so that the assessee knew why the revision failed and the decision could be properly reviewed.

Conclusion: The orders of the Board of Revenue could not be sustained and were quashed, with the matter remitted for fresh determination after hearing the petitioner.

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