Reasoned assessment orders are mandatory: unreasoned allowance and rejection of deduction claims was quashed and remanded.

An assessment order dealing with deduction claims under the Orissa Value Added Tax framework was unsustainable because it allowed some claims and rejected others without recording reasons. The court held that an administrative or quasi-judicial order affecting civil consequences must disclose the basis for acceptance and rejection so that the decision is supported by discernible reasoning. In the absence of reasons, the order was contrary to natural justice. The assessment order was therefore quashed and the matter remanded to the Assessing Officer for fresh consideration after giving the assessee an opportunity to explain the claims.

---

---

Issues: Whether the assessment order rejecting and allowing deduction claims without recording reasons was violative of natural justice and liable to be quashed, and whether the matter was liable to be remanded for fresh assessment.

Analysis: The assessment order under Section 42 of the Orissa Value Added Tax Act, 2004 dealt with the assessee's deduction claims under Rule 6(e) of the Orissa Value Added Tax Rules, 2005, but while allowing some heads and rejecting others, it did not disclose the reasons for either course. An administrative or quasi-judicial order affecting civil consequences must state the basis of acceptance and rejection so that the conclusion is supported by discernible reasoning. In the absence of reasons, the order could not be sustained and was found to be contrary to the principles of natural justice.

Conclusion: The assessment order was quashed for want of reasons and the matter was remanded to the Assessing Officer for fresh consideration after giving the assessee an opportunity to explain the claims.

---