Reasoned assessment orders are mandatory; an unsupported conclusion was set aside and remitted for fresh consideration.

A quasi-judicial assessment order must disclose the reasons supporting its conclusion; a bare assertion that bio-toilet tanks did not fall within the category of rail coaches was insufficient. Because the impugned order contained no reasoning, it could not be sustained and was set aside. The assessing authority was required to pass a fresh reasoned order after giving the affected party an opportunity of personal hearing, and the matter was remitted for reconsideration in accordance with law.

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Issues: Whether the assessment order was liable to be set aside for want of reasons and the matter remitted for fresh consideration.

Analysis: The assessment order merely recorded that the bio-toilet tanks did not fall within the category of rail coaches, without indicating the basis for that conclusion. A quasi-judicial authority is required to support its decision with reasons, and an assessment cannot rest on a bare assertion unsupported by reasoning. Since the impugned order was bereft of reasons, it could not be sustained.

Conclusion: The assessment order was set aside and the assessing authority was directed to pass a fresh reasoned order after affording an opportunity of personal hearing.

Final Conclusion: The writ petition succeeded on the limited ground of absence of reasons, and the assessment was remitted for reconsideration in accordance with law.

Ratio Decidendi: A quasi-judicial assessment order must disclose reasons for the conclusion reached, and an order unsupported by reasons is liable to be set aside and remitted for fresh decision.

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