Appellate orders must address all material submissions; omission to consider a written ground justified remand for fresh reasoned decision.

An appellate authority must consider and address all material submissions, with reasons for accepting or rejecting them. Where a written contention on subsequent-period refund and differential treatment of similar transactions was specifically raised but left undecided, the appellate order could not be sustained. The impugned order was therefore set aside and the matter remanded to the Commissioner (Appeals) for fresh consideration of the submissions and for passing a reasoned order.

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Issues: Whether the refund rejection could be sustained when the appellate authority had not considered the assessee's specific submission regarding subsequent-period refund and differential treatment for similar transactions.

Analysis: The record showed that a specific written submission was made before the Commissioner (Appeals), but no finding was returned on that contention. An appellate order is required to deal with all material submissions and record reasons for acceptance or rejection. Since the impugned order omitted consideration of a relevant ground, it was not sustainable.

Conclusion: The impugned order was set aside and the matter was remanded to the Commissioner (Appeals) for fresh consideration of the submissions and for passing a reasoned order.

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