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Issues: Whether the appellate order could be sustained when it affirmed the assessment without recording reasons and without a meaningful adjudication on the merits, and whether the matter required remand for fresh consideration.
Analysis: A quasi-judicial order affecting civil consequences must disclose reasons. Reasons are the link between the material considered and the conclusion reached, ensure transparency and fairness, and enable judicial review. An order that merely confirms the lower authority without independent reasoning reflects non-application of mind and arbitrariness. Where the appellate authority does not pass a speaking order, the order cannot be sustained in law.
Conclusion: The appellate order was unsustainable for want of reasons and was quashed, and the matter was remanded to the appellate authority for fresh consideration after affording opportunity of hearing.