Reasoned revisional orders under Section 264 are mandatory when tax relief is sought and remand follows cursory disposal.

A revisional authority under Section 264 of the Income-tax Act must pass a reasoned order after considering the material and granting an opportunity of hearing. An order that declines relief without dealing with the merits, and relies only on the availability of a departmental remedy against an ITAT decision, does not show application of mind. The impugned revisional order was therefore set aside and the matter remanded for fresh consideration on merits.

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Issues: Whether the revisional order under Section 264 of the Income-tax Act, 1961 was liable to be set aside for want of reasons and whether the matter should be remanded for fresh consideration.

Analysis: The impugned order declined relief without dealing with the merits of the controversy and rested only on the premise that the departmental remedy against an ITAT decision was still open. Such a cursory disposal did not reflect application of mind to the assessee's claim or the controversy raised in the revision petition. A revisional authority was required to pass a reasoned order after considering the material placed before it and granting an opportunity of hearing.

Conclusion: The order was set aside and the matter was remanded to the revisional authority for passing a reasoned order after hearing the petitioner.

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