Reasoned assessment orders must address objections and disclose relied-on material, or they risk being set aside for unfair hearing.

A quasi-judicial assessment order is invalid where it fails to deal with the assessee's detailed objections and does not record reasons on the material issues, because such omission shows non-application of mind. The order is also vitiated if it relies for the first time on an enforcement-wing proposal that was not disclosed in the show-cause notice, since undisclosed material denies the assessee a fair opportunity to respond. On these defects, the Madras HC set aside the assessment order and permitted fresh assessment after granting reasonable opportunity in accordance with law.

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Issues: Whether the assessment order classifying the goods was vitiated for non-application of mind to the objections and for non-disclosure of the enforcement-wing proposal relied upon.

Analysis: The assessment order was found not to have dealt with the detailed objections raised by the assessee. A quasi-judicial assessment must consider all relevant objections and record reasons dealing with them; failure to do so amounts to non-application of mind. The order also introduced, for the first time, reliance on a proposal from the enforcement wing, which had not been disclosed in the show-cause notice, thereby depriving the assessee of an opportunity to answer that material.

Conclusion: The assessment order was vitiated and was set aside.

Final Conclusion: Fresh assessment was permitted after granting reasonable opportunity to the assessee in accordance with law.

Ratio Decidendi: A quasi-judicial assessment order is invalid if it fails to deal with the material objections raised by the assessee and relies on undisclosed material, as both defects offend the duty to pass a reasoned order and the requirements of fair hearing.

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