Reasoned administrative orders are required for discretionary tax decisions; unreasoned rejection was set aside and remitted.

A discretionary order under Section 62(7) of the Madhya Pradesh Commercial Tax Act, 1994 must reflect application of mind and record cogent reasons. An unreasoned rejection of a dealer's application prevents judicial scrutiny and is liable to interference in writ jurisdiction. Because the State's order gave no reasons, it could not be sustained. The matter was remitted to the State authorities for a fresh decision on merits after granting an opportunity of hearing and recording reasons.

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Issues: Whether an order passed by the State under Section 62(7) of the Madhya Pradesh Commercial Tax Act, 1994 rejecting a dealer's application without recording reasons is sustainable in law.

Analysis: Section 62(7) confers a discretionary power on the State Government to consider a dealer's application for directions to the Commissioner, and the exercise of that power necessarily requires application of mind and disclosure of reasons. An unreasoned rejection prevents judicial scrutiny, indicates non-application of mind, and is liable to be interfered with in writ jurisdiction. Since the impugned order contained no cogent reasons, it could not be sustained.

Conclusion: The rejection order was set aside and the matter was remitted to the State authorities for fresh decision on merits after granting an opportunity of hearing and recording cogent reasons.

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