Revisional order set aside for failure to meaningfully address assessee objections before proceeding with revision

The revisional authority was found to have noted the assessee's written objections but failed to examine them in a meaningful manner before relying on an earlier precedent. Because the impugned revision order did not properly address the objections raised against the proposed revision, it was held unsuitable to stand on its existing reasoning. Without deciding the merits or the jurisdictional objections, the appropriate course was fresh reconsideration after dealing with the objections. The revision order was set aside and the matter remanded to the revisional authority for a fresh decision in accordance with law.

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Issues: Whether the revisional order was liable to be set aside and the matter remanded for fresh consideration because the revisional authority did not deal with the assessee's objections.

Analysis: The revisional authority noted the assessee's written objections but did not examine them in a meaningful manner and instead proceeded to rely on the earlier precedent. The impugned order therefore lacked consideration of the objections raised against the proposed revision. Without entering into the merits of the controversy or the jurisdictional objections, the appropriate course was to require the authority to reconsider the matter after addressing the objections.

Conclusion: The revision order was set aside and the matter was remanded to the revisional authority for fresh decision in accordance with law.

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