Lack of factual discussion and reasons justified remand for fresh reconsideration of the exemption dispute.

Where the authorities failed to discuss the material facts or give reasons for their conclusions, the proper course was remand for fresh adjudication. The High Court set aside the impugned appellate and tribunal orders and directed the Commissioner to reconsider the exemption dispute afresh, taking into account the rival contentions, the relevant factual matrix, the earlier decisions cited by the parties, the statutory amendment, and Circular No. 21/2016. The substantive questions were left open for determination on remand.

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Issues: Whether the matters required remand because the authorities below had not considered the factual matrix or recorded reasons, and whether the Commissioner was required to reconsider the exemption issue afresh.

Analysis: The orders under challenge were found to suffer from absence of discussion on the factual matrix and from want of reasoning as to the basis of the conclusions reached. In these circumstances, the proper course was to send the matters back for a fresh decision. The Commissioner was directed to consider the rival contentions, the relevant factual matrix, the earlier decisions referred to by the parties, the statutory amendment, and Circular No. 21/2016 dated 27th May, 2016.

Conclusion: The matters were remanded for fresh adjudication and the substantive questions were left open.

Final Conclusion: The impugned appellate and tribunal orders were set aside and the exemption dispute was restored for reconsideration in accordance with law.

Ratio Decidendi: Where the authorities below have not discussed the material facts or assigned reasons for their conclusions, the matter may be remanded for fresh decision after due consideration of all relevant contentions and legal developments.

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