The petitioner contested two main points: the adjudication order dated July 3, 2023, which determined tax liabilities and penalties, and an earlier order from July 6, 2022, that blocked the credit ledger. However, the challenge to the latter order was rendered moot, as the credit ledger had since been unblocked.

The court highlighted a critical shortcoming in the adjudication order. Although the petitioner submitted a detailed response to a show cause notice issued in August 2022, the adjudicating officer’s subsequent order contained no substantive reasoning for its conclusions. The order merely stated that tax, interest, and penalties were demandable, without engaging with the arguments presented by the petitioner.

The court emphasized that providing reasons is an essential aspect of natural justice and fair play. A reasoned decision serves as a vital link between the decision-maker's thought process and the final ruling. It allows the appellate authority to understand the basis of the decision and ensures that the rights of the parties involved are upheld.

The court referred to established legal principles, noting that decisions devoid of reasons undermine the right to appeal—a right that is fundamental to the justice system. The absence of a reasoned order was deemed a failure of natural justice, rendering the original ruling unsustainable.

As a result of these findings, the court set aside the impugned order and remanded the matter back to the Deputy Commissioner of State Tax for fresh adjudication. The court mandated that the officer must provide a reasoned, speaking order within six weeks, ensuring that all parties' contentions are duly considered.

This case serves as a potent reminder of the importance of reasoned decision-making in judicial and quasi-judicial contexts. The ruling reinforces that mere conclusions without justification do not meet the standards of fairness and transparency required in tax adjudication. As such, tax authorities must not only make decisions but also articulate the reasoning behind them, safeguarding the rights of taxpayers and maintaining the integrity of the judicial process.