Appellate order must address each legal objection before sustaining tax demands; matter remanded for fresh findings.

An appellate order on taxability, limitation, exemption and penalties was unsustainable because the appellate authority had not dealt with the appellant's legal objections or recorded findings on each issue raised. The matter also required consideration of the appellant's contention that similarly placed contractors had been treated differently. The impugned order was therefore set aside and the dispute was remanded to the Commissioner (Appeals) for a fresh decision with specific findings on all issues.

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Issues: Whether the impugned order could be sustained when the appellate authority had not considered the appellant's legal objections and was required to record findings on each issue raised.

Analysis: The appeal involved multiple disputes concerning taxability, limitation, exemption, and penalties. The order under challenge had not dealt with the legal issues in detail. In such a situation, the matter required reconsideration by the appellate authority with specific findings on each issue, including the appellant's contention regarding similarly placed contractors.

Conclusion: The impugned order was set aside and the matter was remanded to the Commissioner (Appeals) for fresh decision.

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