Adjudicatory treatment of tax liability for parking services...

Adjudicatory treatment of tax liability for parking services must account for material documentary evidence and permit post decisional remedy: where an order rejected a claim that the petitioner acted for a municipal corporation because no Agreement was on file, the court granted liberty to tender supporting documents and required the proper officer to grant a post decisional hearing and decide thereafter; the impugned order was temporar ily held in abeyance and related garnishee proceedings stayed subject to strict filing and decision timetables, and the authority may record supplementary reasons if unconvinced.