Reasoned quasi-judicial orders required; summary rejection of contentions and remand for fresh adjudication followed.

Quasi-judicial orders must record the contentions raised and the findings on them so that the basis of decision is clear to the parties and any reviewing forum. Here, the Tribunal was found to have summarily brushed aside the assessee's arguments, including cited Supreme Court authorities, without identifying the issues or giving reasons. Because the impugned orders disclosed no proper application of mind, they could not be sustained. The matters were therefore set aside and remanded to the Tribunal for fresh notice, hearing, and disposal on the merits in accordance with law.

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Issues: Whether the Tribunal's impugned orders could be sustained when they summarily disposed of the assessee's contentions without recording the issues, the arguments advanced, or findings thereon, and whether the matters should be remitted for fresh adjudication.

Analysis: The Tribunal was found to have brushed aside important legal issues, including cited Supreme Court decisions, by a perfunctory observation that they were distinguishable. It was held that judicial and quasi-judicial forums must record the contentions raised and the findings on them, so that the basis of decision is ascertainable by the parties and any higher forum. Without such reasons, the impugned orders could not stand, and no examination of the merits was undertaken by the Court.

Conclusion: The impugned orders were set aside and the proceedings were remanded to the Tribunal for fresh notice, hearing, and disposal on the merits in accordance with law.

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