2025 (7) TMI 603

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.... 3. It is vociferously submitted by Mr. Rudra Prasad Kar, learned Senior Counsel appearing for the writ petitioner that initially the assessment order was passed after the complete scrutiny under Section 143(3) of the Income Tax Act, but the Principal Commissioner, Bhubaneswar initiated a suo motu revision proceeding of the said assessment order and remitted the matter upon formulating the points for reconsideration by the Assessing Officer. 4. Mr. Kar, learned Senior Advocate was critical on the issue that the authority exercising power of revision should not have remitted the matter on limited points, but should have remitted the matter in its entirety. 5. We do not find any impediment in this regard. In absence of any express embar....

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....rds, it becomes easier to the higher forum to understand the basic foundation of denial of the claims by the assessee so as to uphold or interfere on the well-recognized parameters of law. 8. By passage of time, the concept of passing reasoned order has gained momentum and has expanded its horizon not only from a judicial system but to any quasi-judicial system or in any adjudicatory process which decides the fate of claim made by a person. The order which is bereft of reasons cannot be regarded as an order in eye of law. The reasons not only inheres fairness, transparency but also propagates the decision making process and reflects the minds of an adjudicator with precision and clarity. 9. Even the Apex Court coined such unreasoned o....

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....it came to the conclusion that the officer concerned was found to be not suitable for inclusion in the Select List.' This principle has been extended to administrative actions on the premise that it applies with greater rigour to the judgments of the courts." 10. In a subsequent decision rendered by the Apex Court in Steel Authority of India Ltd. Vs. Sales Tax Officer, Rourkela-I Circle and others, (2008) 9 SCC 407, it has been held:- "17. 7. Reason is the heartbeat of every conclusion. It introduces clarity in an order and without the same it becomes lifeless. (See Raj Kishore Jha v. State of Bihar [(2003) 11 SCC 519 : 2004 SCC (Cri) 212].) 8. Even in respect of administrative orders, Lord Denning, M.R. in Bre....