Reasoned refusal under estate duty law is mandatory; a bare decline without reasons cannot satisfy statutory requirements.

A refusal by the Board to determine estate duty under Section 69 had to rest on relevant considerations, including the complexity of the estate or other statutory causes, and the order had to disclose reasons showing application of mind. A bare communication declining to determine the matter, without reasons, did not meet that requirement. The impugned order was therefore invalid for want of reasons and was quashed, with a direction to reconsider the matter afresh and pass appropriate orders.

---

---

Issues: Whether the order of the Central Board declining to determine estate duty under Section 69 of the Estate Duty Act was valid without recording reasons.

Analysis: The provision required the Board to consider whether, because of the complexity of the estate or other relevant causes, composition and assessment on that basis were justified. A refusal under the section had to be based on relevant considerations and reflected in the order. A bare communication stating only that the Board declined to determine the matter, without reasons, did not disclose application of mind to the statutory requirements and could not satisfy the obligation under Section 69.

Conclusion: The impugned order was invalid for want of reasons and was quashed, with a direction to the Board to reconsider the matter afresh and pass appropriate orders.

---