Unclear factual basis for separate accounts requirement led to remand for fresh adjudication and reconsideration.

Where the identity of the inputs and the stage at which they were used in manufacture were not clearly established, the basis for deciding whether separate accounts were required remained uncertain. The original authority proceeded on the assumption that the inputs were common inputs, but the record did not specify the impugned inputs or their use in the manufacturing process. In these circumstances, the findings of the Commissioner (Appeals) and the original authority could not be sustained without a fresh examination of the factual matrix. The matter was therefore remanded to the original authority for reconsideration after giving the respondent a reasonable opportunity of hearing.

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Issues: Whether the matter required remand for fresh consideration in the absence of clarity regarding the identity of the inputs and the stage at which they were used in the manufacturing process for determining the applicability of the requirement to maintain separate accounts.

Analysis: The order of the original authority did not specify the impugned inputs or the stage at which they were introduced in the manufacturing process, yet proceeded on the footing that they were common inputs and that separate accounts had not been maintained. The absence of clarity on these basic facts meant that the foundation for the demand was uncertain. In these circumstances, the findings of the Commissioner (Appeals) and the original authority could not be sustained without fresh examination of the relevant factual matrix.

Conclusion: The matter was rightly remanded to the original authority for fresh consideration after giving reasonable opportunity of hearing to the respondent.

Final Conclusion: The appeal succeeded, and the dispute was sent back for reconsideration on the basis of a properly established factual record.

Ratio Decidendi: Where the basic facts necessary to determine whether inputs were common and whether separate accounts were required are unclear, the proper course is remand for fresh adjudication.

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