Reasoned tax assessment orders are essential; mechanical VAT findings on pest control services were set aside and remitted.

Tax assessment orders levying value added tax on pest control services were held unsustainable where they were largely mechanical and failed to show adequate reasons or objective consideration of the assessee's objections. A quasi-judicial assessment must disclose application of mind and the basis of the conclusion so that the affected party and the reviewing court can understand why tax liability was imposed. Because the orders did not permit meaningful judicial review, they were set aside and the matters remitted for fresh consideration in accordance with law.

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Issues: Whether the assessment orders levying tax on pest control services under the value added tax law, without adequate reasons and objective consideration of the objections, could be sustained.

Analysis: The assessment orders were found to be largely mechanical, as they reproduced the objections and earlier material but contained only a cursory conclusion on taxability. A quasi-judicial assessment order must disclose application of mind and the reasons that led to the conclusion, so that the affected party and the reviewing court can understand the basis of the decision. The absence of objectivity and adequate reasons made meaningful judicial review impossible. In such circumstances, the proper course was to set aside the orders and remit the matters for fresh consideration in accordance with law.

Conclusion: The assessment orders were unsustainable and were set aside, with a direction for fresh orders to be passed after proper consideration.

Ratio Decidendi: A tax assessment order passed in a quasi-judicial capacity must be a reasoned order showing application of mind; if it is bereft of adequate reasons and objective consideration, it cannot be sustained and may be remanded for fresh decision.

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