Quasi-judicial assessment orders in disciplinary proceedings require reasoned consideration; a non-speaking order was set aside and remanded.

A disciplinary challenge arising from an income-tax assessment order had to be tested against the petitioner's claim that the act was quasi-judicial and done in good faith, and could not be treated as misconduct merely because another view was possible absent allegations of corruption or recklessness. The Delhi HC found the Tribunal had not engaged with these core objections and had disposed of the matter cursorily despite serious consequences for the petitioner. The impugned order was therefore set aside, and the matter was remitted for fresh consideration by a speaking order.

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Issues: Whether the Tribunal's order sustaining the charge memo against the petitioner, without dealing with the petitioner's contention that the assessment order was passed in a quasi-judicial capacity and in good faith, warranted interference and remand for a fresh speaking order.

Analysis: The charge memo arose from an assessment order passed by the petitioner under the Income-tax Act, 1961. The petitioner's case was that the order was made in the exercise of quasi-judicial powers and could not be treated as a disciplinary lapse merely because another view was possible, absent allegations of corruption, recklessness, or similar exceptional circumstances. The Tribunal's order did not engage with these core submissions and disposed of the matter in a cursory manner, even though the disciplinary action had serious consequences for the petitioner. In such circumstances, the absence of a proper and reasoned consideration rendered the Tribunal's approach unsatisfactory.

Conclusion: The impugned order was set aside and the matter was remitted to the Tribunal for fresh consideration and disposal by a speaking order.

Ratio Decidendi: A disciplinary challenge arising from a quasi-judicial act must be considered on its relevant legal objections and decided by a reasoned order; a non-speaking disposal that ignores those objections is liable to be set aside and remanded.

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