Non-speaking order on assessable value and suppression cannot justify extended-period demand without considering material evidence.

An order on assessable value and suppression cannot stand where the authority fails to deal with the taxpayer's material plea and evidence, including sales to independent wholesale dealers at the same price. The record also showed prior disclosure of the holding company relationship and pricing basis, which weakened the allegation of suppression and undermined invocation of the extended period. The matter therefore required fresh adjudication after considering the evidence and cited case law, with a speaking order passed after hearing the taxpayer.

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Issues: Whether the impugned order was a non-speaking order for failure to consider the appellants' material plea regarding independent sales at the same price and whether the invocation of the extended period on the ground of suppression could stand.

Analysis: The record showed that the appellants had specifically relied on sales to independent wholesale dealers at the same price as evidence of the correct assessable value, yet the original authority did not deal with that contention in detail. The Department was also aware, through contemporaneous correspondence in 1991, that the holding company relationship and the pricing basis had been disclosed, which weakened the allegation of suppression. In these circumstances, the reasoning on extended period and suppression was held to be incomplete, and the matter required reconsideration after taking the relevant evidence and cited case law into account.

Conclusion: The impugned order could not be sustained and the matter was required to be remanded for de novo adjudication after hearing the appellants and passing a speaking order.

Ratio Decidendi: Where material submissions and evidence bearing on assessable value and suppression are not considered, the resulting order is non-speaking and cannot sustain invocation of the extended period.

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