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Issues: Whether the unreasoned order of the Tribunal, which recorded contentions but did not decide the grounds on merits, was liable to be quashed and the appeal restored for fresh consideration.
Analysis: The impugned order did not deal with the substantial questions raised before the Tribunal and merely noted the rival submissions without recording reasons for the conclusion reached. A judicial or quasi-judicial determination must disclose reasons, especially where multiple grounds affecting jurisdiction, limitation, penalty, and statutory liability are raised. In the absence of any consideration on merits, the order could not stand.
Conclusion: The order was quashed and set aside, and the matter was remanded to the Tribunal for fresh disposal on merits, with all contentions left open.