Reasoned assessment orders are mandatory where objections are raised; unreasoned rejection led to quashing and remand.

A revisional assessment order that rejects dealer objections without recording reasons is unsustainable because a civil-consequences order must disclose why the objections fail. The court noted that notice and reply had already provided a reasonable opportunity, so the defect was not in the hearing process but in the absence of reasoned rejection. The proper course was to quash the revised assessment orders and remand the matter for fresh assessment after considering the objections and giving reasons for their disposal.

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Issues: Whether the revised assessment orders were liable to be set aside for not dealing with the dealer's objections and not giving reasons for rejecting them; and whether the matter should be remanded for fresh revised assessment after considering the objections already filed.

Analysis: The impugned orders were passed after revisional notices and replies, but the rejection of the objections was recorded only in a single sentence without any indication of why the objections were unacceptable. A revisional assessment order affecting civil consequences must disclose reasons, especially when objections have been filed in response to a show-cause notice. The statutory scheme also contemplated a reasonable opportunity before revised assessment, and that requirement stood satisfied because notices had already been issued and detailed objections had been submitted. Since the core defect was the absence of reasons, the appropriate course was to quash the orders and require the authority to pass fresh revised assessment orders by adverting to the objections and recording reasons.

Conclusion: The revised assessment orders were set aside and the matter was remanded for fresh orders after considering the objections and giving reasons for their rejection.

Final Conclusion: The assessee obtained relief by securing quashing of the impugned assessment orders, but the revenue authority was permitted to redo the assessments in accordance with law after dealing with the objections.

Ratio Decidendi: A revisional or assessment order that rejects objections without reasons is unsustainable, and where prior notice and reply have been given, the proper remedy is quashing with a direction for a fresh reasoned order.

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