Speaking reassessment orders are required where objections are raised; unexplained adjustments and additions cannot stand.

Reassessment orders under the Value Added Tax Act were held unsustainable where they did not disclose the assessee's objections, the manner of their consideration, or reasons for rejecting them. An assessment order must show application of mind and give reasons for adjustments and additions, particularly when objections are raised. The absence of a meaningful hearing and of speaking reasons meant the orders could not stand, and the matter was directed to be reconsidered after due opportunity to the assessee.

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Issues: Whether the reassessment orders were liable to be set aside for want of effective opportunity of hearing and for being non-speaking and unsupported by reasons.

Analysis: The assessments were made pursuant to inspection findings and notices proposing revision under section 84 of the Value Added Tax Act, 2006. Though objections were stated to have been received, the assessment orders did not disclose the contents of those objections, the manner in which they were considered, or the reasons for rejecting them. An assessment order must reflect application of mind and contain reasons for the adjustments and additions made, especially when objections are raised by the assessee. The impugned orders failed to meet this standard and did not disclose a meaningful opportunity of hearing.

Conclusion: The reassessment orders were rightly set aside and the matter was directed to be redone after affording due opportunity to the assessee.

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