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Issues: Whether the draft assessment objections had been dealt with by the Dispute Resolution Panel by a speaking order and, if not, whether the matter should be remitted for fresh adjudication.
Analysis: The assessee's objections and material placed before the Dispute Resolution Panel were not discussed issue-wise, and the order did not disclose consideration of the relevant facts, contentions, or paper books. An adjudicatory order affecting rights must record reasons so that the parties and the appellate forum can understand the basis of the decision and test its legality.
Conclusion: The Dispute Resolution Panel order was held to be non-speaking and was set aside, with the matter remitted to the Dispute Resolution Panel for reconsideration.
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