Speaking order requirement led to partial remand where VAT on infra lease and mess charges lacked reasons.

A quasi-judicial assessment order must contain reasons, especially when objections to a proposed levy are rejected. A bare conclusion that an explanation is unsatisfactory does not amount to a speaking order and denies effective adjudication and natural justice. The order here gave no reasons for sustaining VAT on infra lease and mess charges, so it was set aside to that extent. Those issues were remitted for fresh consideration with a personal hearing and a reasoned order, and the petitioner succeeded only in part.

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Issues: Whether the assessment order sustaining VAT on infra lease and mess charges was vitiated for want of reasons and whether the matter required remand for fresh consideration.

Analysis: A quasi-judicial authority must support its conclusion with reasons, particularly when rejecting objections to a proposed levy. A bare statement that the explanation is not satisfactory does not meet the requirement of a speaking order. The absence of reasons also deprives the assessee of effective adjudication and violates principles of natural justice. The impugned order gave no reasons for sustaining VAT on infra lease and mess charges.

Conclusion: The order was set aside only to the extent it upheld VAT on infra lease and mess charges, and those issues were remitted for fresh consideration with a personal hearing and a reasoned order. The petitioner succeeded only in part.

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