Quasi-judicial orders must stand on recorded reasons; later affidavits cannot cure a defective refund rejection.

Refund claims under Section 50 of the Assam VAT Act and Rule 29 of the Assam VAT Rules must ordinarily be filed within 180 days of assessment or reassessment, but delayed claims may still be admitted on sufficient cause. A refusal of delay condonation must record reasons showing why the explanation was rejected. Here, the rejection order only stated that proof of timely filing was not furnished and did not examine the explanation, assessment records, or refund entitlement. The High Court held that a quasi-judicial order must stand on its own reasons, so a later affidavit could not cure the omission. The impugned rejection was set aside and the matter remanded for fresh decision.

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Issues: Whether the rejection of the refund claim as time-barred was sustainable, and whether the authorities could justify the rejection by later affidavit instead of the reasons recorded in the order.

Analysis: The refund provisions under Section 50 of the Assam Value Added Tax Act, 2003 and Rule 29 of the Assam Value Added Tax Rules, 2005 require a claim to be filed within 180 days from assessment or reassessment, but the prescribed authority retains discretion to admit a delayed application on sufficient cause being shown. If a delayed claim is refused, the authority must disclose reasons showing why the explanation was not accepted. The impugned order merely stated that proof of timely filing was not furnished and that the application was rejected for delay. It did not address the explanation offered, did not refer to the underlying assessment records or refund entitlement, and did not disclose any meaningful enquiry on the issue of delay. The subsequent affidavit attempting to supply these omissions could not enlarge or improve the original quasi-judicial order, which must stand or fall on the reasons recorded in it.

Conclusion: The rejection of the refund claim was unsustainable, and the writ petitioner succeeded to the extent that the impugned order and communication were set aside and the matter was remanded for fresh decision on refund.

Ratio Decidendi: A quasi-judicial order must be tested only on the reasons stated in the order itself, and a deficient order cannot be validated by fresh reasons later supplied through affidavit.

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