Reasoned valuation orders must link freight inclusion to contract terms and evidence; unsupported findings were set aside and remanded.

A duty valuation order cannot be sustained where it treats the buyer's premises as the place of removal and includes freight in assessable value without disclosing the specific contractual clauses or evidence relied on. The tribunal found the reasoning inadequate because the conclusions were not clearly linked to the underlying purchase orders and delivery terms, and the order therefore failed the requirement of a speaking order. It was set aside and the matter remanded for fresh adjudication with explicit reasons, supporting evidence, and observance of natural justice.

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Issues: Whether the impugned order, which treated the buyer's premises as the place of removal and upheld inclusion of freight in assessable value, was a speaking order supported by the contract terms and evidence.

Analysis: The impugned order recorded conclusions on the basis of purchase orders and delivery terms, but did not identify the exact contractual clauses or supporting evidence from which those conclusions were drawn. In the absence of a clear link between the findings and the underlying contractual material, the order was found to be inadequately reasoned. The matter therefore required fresh consideration with explicit reasons and supporting evidence, and with observance of natural justice.

Conclusion: The impugned order was set aside and the matter was remanded for fresh adjudication.

Final Conclusion: The assessee succeeded in having the order annulled at this stage, and the dispute was sent back for reconsideration on a properly reasoned basis.

Ratio Decidendi: A duty demand order affecting valuation cannot be sustained when it records conclusions without disclosing the contractual or evidentiary basis for those findings; such an order is liable to be set aside and remanded for fresh decision.

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