Reasoned assessment orders require real consideration of objections; perfunctory rejection without analysis is unsustainable.

Assessment orders must deal with the objections raised in reply to a show-cause notice and must record reasons. Where an order merely states that the contentions are not tenable, without any discussion or analysis, it reflects non-application of mind and is vulnerable as unreasoned and perverse. Such perfunctory disposal cannot withstand judicial scrutiny and may be set aside, with liberty to pass fresh orders after properly considering the objections.

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Issues: Whether the assessment orders were liable to be quashed for failure to consider the objections raised in response to the show-cause notices and for being unreasoned and perverse.

Analysis: The assessment orders disclosed no consideration or analysis of the dealers' objections and merely recorded that the contentions were not tenable. Such a perfunctory disposal showed a total non-application of mind and a failure to give reasons. Orders made in this manner cannot stand judicial scrutiny and are liable to be set aside.

Conclusion: The assessment orders were quashed, with liberty to pass fresh orders after duly considering the objections.

Final Conclusion: The writ petitions succeeded and the impugned assessments were set aside for want of proper consideration and reasons.

Ratio Decidendi: An assessment order that fails to deal with the objections raised and does not record reasons is unsustainable for non-application of mind and perversity.

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