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Issues: Whether the Sales Tax Appellate Tribunal was required to independently consider the assessee's contentions and record reasons, and whether its cryptic order warranted remand for fresh disposal.
Analysis: The assessment was reopened under section 19 of the Kerala General Sales Tax Act, 1963 on the basis of alleged unaccounted inter-State purchases. The first appellate authority had rejected the assessee's main contention but granted partial relief. The Tribunal, however, affirmed that order in a brief order without discussing the evidence or the objections raised. As the last fact-finding authority, the Tribunal was obliged to independently examine the materials, consider the submissions, and give a reasoned decision rather than merely endorse the lower appellate order.
Conclusion: The Tribunal's order was unsustainable for want of independent reasoning, and the matter was rightly remitted to the Tribunal for fresh disposal in accordance with law.
Ratio Decidendi: A final fact-finding appellate authority must independently evaluate the evidence and record a reasoned order; a cryptic affirmance without consideration of the contentions is liable to be set aside and remanded.