Reasoned orders requirement: non-speaking rejection and consequential demand notices were set aside for fresh reconsideration.

A rejection of a claim under G.O. Ms. No. 43 was set aside because it was a non-speaking order that gave no reasons. The Court held that an order rejecting a claim must disclose reasons to withstand judicial scrutiny, and the consequential demand notices could not survive once the foundation order failed. The matter was remitted for fresh consideration of the applicability of G.O. Ms. No. 43 to the case, while leaving it open to the assessing officer to proceed in accordance with the statutory provisions for the relevant assessment years.

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Issues: Whether the rejection of the petitioner's claim for benefit under G.O. Ms. No. 43, without reasons, was sustainable in law, and whether the consequential demand notices and the matter required reconsideration.

Analysis: The rejection of the petitioner's claim was made without assigning reasons. An order rejecting a claim must disclose reasons, and a non-speaking order cannot stand judicial scrutiny. Since the demand notices followed the rejection order, they were consequential to it. The dispute as to the applicability of G.O. Ms. No. 43 to the petitioner's case therefore required fresh consideration by the competent authority. The Court also left it open to the assessing officer to proceed in accordance with the statutory provisions for the relevant assessment years.

Conclusion: The non-speaking rejection order was unsustainable, the consequential notices were set aside, and the matter was remitted for reconsideration of the applicability of G.O. Ms. No. 43 to the petitioner's case.

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