Reasoned assessment orders and disclosure of third-party records are essential for a valid revision under tax law.

A revised assessment order was found unsustainable because the revisional authority rejected the assessee's objections without giving reasons. The Court reiterated that an authority exercising statutory power must record reasons, since a non-speaking order impairs the assessee's effective appellate remedy. It also held that where reliance is placed on third-party records, copies of those materials must be furnished to enable a meaningful reply. On these grounds, the revised assessment was set aside, with liberty to pass a fresh order after considering the objections and supplying any third-party records relied upon.

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Issues: Whether the revised assessment order was sustainable when the objections of the assessee were overruled without reasons and the third-party records relied on were not furnished to enable an effective reply.

Analysis: The assessment was revised after issuing a pre-revision notice. The assessee specifically objected that the goods were second schedule goods and that the proviso to Section 3(2) of the Act was inapplicable, but the revisional authority merely stated that the objections were not acceptable and overruled them. The order contained no reasons for rejecting the objections. The Court held that an authority exercising statutory power must record reasons, and absence of reasons deprives the assessee of an effective remedy in appeal. It was also noted that if reliance is placed on third-party records, copies of such materials must be furnished so that the assessee can meet them.

Conclusion: The revised assessment order was unsustainable and was set aside. The respondent was permitted to pass fresh orders after considering the objections and, if third-party records were relied upon, to furnish copies to the assessee.

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