Reasoned Dispute Resolution Panel orders are mandatory; a bare referral back to the Assessing Officer was set aside.

A Dispute Resolution Panel exercising objection-review jurisdiction under Section 144C of the Income-tax Act must apply its mind to the objections and issue reasoned directions; an order that merely notes the assessee's submissions and tells the Assessing Officer to consider them is unsustainable. The absence of independent reasoning and effective directions showed non-application of mind, so the order was set aside and the matter remitted to the Panel for fresh consideration in accordance with law.

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Issues: Whether the Dispute Resolution Panel's order, which merely noted the assessee's submissions and directed the Assessing Officer to consider them, was liable to be set aside for want of reasoning and application of mind.

Analysis: The impugned order contained no independent reasoning on the objections raised and did not issue any effective directions to guide the Assessing Officer, although the statutory framework under Section 144C of the Income-tax Act, 1961 requires the Panel to consider the objections and give directions. An order that simply forwards the matter to the Assessing Officer without addressing the controversy or recording any reasoned determination does not satisfy the requirement of due application of mind.

Conclusion: The order was unsustainable and was set aside.

Final Conclusion: The writ petition succeeded and the matter was remitted to the Dispute Resolution Panel for fresh consideration in accordance with law.

Ratio Decidendi: A statutory panel exercising objection-review jurisdiction must render a reasoned decision and cannot discharge its function by merely referring the matter back to the assessing authority without applying its mind to the objections raised.

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