Merits-based appellate adjudication is mandatory; non-participation cannot justify dismissing an appeal without reasoned consideration of jurisdictional grounds.

The Commissioner (Appeals) must decide an income-tax appeal on merits in writing, identify the points arising from the assessment under challenge, and record reasons for the decision. Non-participation by the assessee does not permit summary dismissal for want of prosecution, particularly where the grounds challenge the Assessing Officer's jurisdiction. The notes state that such dismissal is invalid and that the matter should be restored for fresh adjudication after a reasonable opportunity of hearing.

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Issues: Whether the Commissioner (Appeals) could dismiss the assessee's appeal for want of prosecution without adjudicating the grounds raised.

Analysis: Although an appellate proceeding need not be stalled by an assessee's non-participation, the Commissioner (Appeals) is statutorily required to decide the appeal in writing by determining the points arising from the challenged assessment and recording reasons. The appellate powers require adjudication on merits and do not permit summary dismissal merely because the appellant did not effectively participate. This was material because the grounds included a challenge to the Assessing Officer's assumption of jurisdiction.

Conclusion: The dismissal for want of prosecution was invalid. The matter was restored to the Commissioner (Appeals) for fresh adjudication after granting the assessee a reasonable opportunity of hearing.

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