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First appellate authorities must examine assessment issues and decide appeal grounds through a reasoned, speaking order even when the appellant is absent; statutory appeals should not ordinarily be dismissed solely for non-prosecution without merits adjudication. In reassessment concerning unexplained cash deposits, contemporaneous material plausibly explaining non-representation required an effective opportunity to substantiate the depositor's explanation. The appellate order was set aside and the reassessment dispute remanded to the Assessing Officer for fresh adjudication after reasonable and effective hearing, subject to the assessee's cooperation and production of supporting evidence.
First appellate authorities must examine assessment issues and decide appeal grounds through a reasoned, speaking order even when the appellant is absent; statutory appeals should not ordinarily be dismissed solely for non-prosecution without merits adjudication. In reassessment concerning unexplained cash deposits, contemporaneous material plausibly explaining non-representation required an effective opportunity to substantiate the depositor's explanation. The appellate order was set aside and the reassessment dispute remanded to the Assessing Officer for fresh adjudication after reasonable and effective hearing, subject to the assessee's cooperation and production of supporting evidence.
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