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Issues: Whether the order rejecting the claim for sales tax exemption was liable to be quashed for absence of reasons, and whether any relief could still be granted on the facts.
Analysis: The order impugned was non-speaking and merely referred to the notification without assigning reasons. A public authority is required to pass a reasoned order, since reasons are the basis of fair procedure and guard against arbitrariness. The requirement to record reasons applies even in administrative matters unless expressly excluded, and it is part of natural justice and fair play in action. However, the claim was raised at a belated stage, the exemption was available only for a particular period, and the record did not establish that the industrial unit was in commercial production when the application was considered. In these circumstances, discretionary relief was not warranted.
Conclusion: The rejection order was found to be unspeaking and deficient in reasons, but the petitioners were not entitled to any relief on the facts.
Ratio Decidendi: An administrative or statutory order affecting rights must be supported by reasons, but writ relief may still be refused where the claim is belated and the factual foundation for the benefit is not established.