Reasoned assessment orders are mandatory; a non-speaking tax order was set aside and remanded for fresh consideration.

An assessment order that merely reproduces the taxpayer's reply and confirms the tax proposal without giving reasons cannot be sustained, because liability determinations must disclose the basis for the decision. The Madras HC therefore set aside the order and remanded the matter for fresh consideration, directing the authority to grant a reasonable opportunity of hearing, including personal hearing, and to pass a fresh order within the stipulated time.

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Issues: Whether the assessment order was liable to be set aside for want of reasons and whether the matter should be remanded for fresh consideration.

Analysis: The impugned order merely extracted the taxpayer's reply and thereafter confirmed the tax proposal without assigning reasons. An order that determines liability without disclosing reasons cannot be sustained. In the circumstances, a fresh decision was warranted with an opportunity of hearing to the petitioner.

Conclusion: The assessment order was set aside and the matter was remanded for reconsideration with a direction to grant a reasonable opportunity, including personal hearing, and pass a fresh order within the stipulated time.

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