Proper verification of evidence and a reasoned hearing are required before disturbing a tax remand order.

Where a first appellate authority has remanded a tax matter for fresh consideration, the Tribunal should not interfere unless it addresses the need for proper verification of the material evidence and the requirement of a reasoned decision after hearing the assessee. The text emphasises that, if purchases and supporting documents remain insufficiently examined, a fuller inquiry by the Assessing Authority is necessary. The operative effect is that the matter should be sent back for fresh adjudication with adequate opportunity to the assessee to place supporting material and with a fresh reasoned order on record.

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Issues: Whether the Tribunal was justified in allowing the assessee's second appeal and setting aside the first appellate authority's remand order, and whether the matter required remand to the Assessing Authority for fresh adjudication after considering the material on record and granting opportunity of hearing.

Analysis: The first appellate authority had remanded the assessment for a fresh reasoned decision after directing consideration of the relevant material. The Tribunal, while allowing the appeal, ignored the reasons recorded in the remand order and did not properly examine whether the goods purchases and supporting evidence placed by the assessee had been duly verified. In the circumstances, a full and proper inquiry by the Assessing Authority was necessary, together with an opportunity to the assessee to place the material in support of its claim.

Conclusion: The Tribunal's order was set aside and the matter was remanded to the Assessing Authority to pass a fresh reasoned order after providing adequate opportunity to the assessee.

Final Conclusion: The revision succeeded and the dispute was sent back for fresh decision by the Assessing Authority.

Ratio Decidendi: Where a first appellate authority has remanded a tax matter for fresh consideration, the Tribunal should not interfere without addressing the need for proper verification of material evidence and compliance with the requirement of a reasoned order after hearing the assessee.

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