Reasoned orders and natural justice require tax authorities to deal with objections before finalising reassessment.

Reassessment orders under the Tamil Nadu Value Added Tax Act were held unsustainable because the assessing authority did not consider the dealer's objections or give reasons on the alleged suppression of sales. A quasi-judicial authority must address the explanation offered, record clear findings on the points in dispute, and pass a speaking order; failure to do so breaches natural justice. The impugned reassessments were quashed, and the matter was remitted for fresh adjudication after hearing the assessee and issuing a reasoned order.

---

---

Issues: Whether reassessment orders passed under Section 22(2) of the Tamil Nadu Value Added Tax Act, 2006 were liable to be quashed for failure to consider the dealer's objections and for being non-speaking orders.

Analysis: The objections filed against reopening were not dealt with in the impugned orders. A quasi-judicial assessing authority is required to address the explanation offered by the assessee and record clear reasons showing due consideration of the points in controversy. Where an explanation is offered to meet the allegation of suppression or non-reporting of sales, the authority must return a finding on that explanation. An order which ignores the objections and contains no reasons violates the principles of natural justice and cannot be sustained.

Conclusion: The reassessment orders were vitiated and were quashed.

Final Conclusion: The matter was sent back for fresh adjudication after granting a hearing to the assessee and passing a reasoned order in accordance with law.

Ratio Decidendi: An administrative or quasi-judicial authority must record reasons and deal with the objections raised before it, and failure to do so renders the order invalid for breach of natural justice.

---