De novo valuation remand requires fresh consideration of all material on record, not just additional evidence.

In remand proceedings on valuation, unless the remand is expressly limited, the adjudicating authority must conduct a fresh de novo determination on all material on record and any additional evidence permitted. The original authority erred by repeating its earlier conclusion without independently examining the existing documents and by treating the remand as confined only to the proposed extra evidence. The proper course was to consider all relevant material, grant a reasonable hearing, and issue a fresh finding on valuation. The remand therefore required independent reconsideration of the dispute on the full record.

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Issues: Whether the remand order required the original authority to undertake a de novo adjudication of the valuation issue by considering all material on record, and whether the appellate authority had erred in treating the matter as confined only to the additional evidence sought to be produced.

Analysis: The remand order had directed fresh adjudication on the valuation dispute and had noted the need to consider the additional evidence proposed by the assessee. That direction did not exclude the evidence already on record. The original authority, however, repeated its earlier conclusion without independently examining the existing documentary material. The proper course in remand proceedings was to assess all relevant documents filed by the assessee, afford a reasonable opportunity of hearing, and then return a fresh finding on valuation. The original authority could not enlarge the remand by considering an order that had not been placed before the Tribunal when the remand was made.

Conclusion: The remand was to be treated as a de novo adjudication on valuation, and the original authority was required to decide the issue afresh on all material available on record.

Ratio Decidendi: In remand proceedings, unless expressly restricted, the adjudicating authority must consider both the existing record and any additional evidence permitted by the remand, and cannot merely repeat the earlier decision without independent application of mind.

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