Reasoned exemption orders required under sales tax law; vague findings and unsupported assumptions led to quashing and remand.

Orders rejecting exemption from sales tax were unsustainable where the authority failed to give cogent reasons or identify which statutory requirements had not been met under section 4-A of the U.P. Sales Tax Act. Allegations of non-compliance, the age of machinery, and non-production of the SSI registration certificate were found vague and unsupported by material, and the review order relied on irrelevant or uninvestigated assumptions. The authority was held to have not applied its mind adequately. The rejection and review orders were quashed, and the matter was remanded for fresh enquiry and disposal by a speaking order after reasonable opportunity of hearing.

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Issues: Whether the orders rejecting the application and review for exemption from sales tax under section 4-A of the U.P. Sales Tax Act could be sustained, or were liable to be quashed and the matter remanded for fresh consideration.

Analysis: The rejection order did not disclose cogent reasons showing which statutory or regulatory requirements had not been satisfied. The grounds regarding alleged non-compliance, the age of machinery, and non-production of the SSI registration certificate were found to be vague and unsupported by material. The review order also proceeded on grounds that were either irrelevant to the exemption claim or based on assumptions not properly investigated. The authority was found to have failed to apply its mind and to have passed orders without adequate reasoning.

Conclusion: The rejection and review orders were not sustainable and were quashed. The matter was remanded to the Divisional Level Committee for fresh enquiry and disposal by a speaking order after giving reasonable opportunity of hearing to the petitioners.

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