Where the Dispute Resolution Panel has brushed a side assessee’s submissions without even a whisper of the assessee’s objections against draft assessment order, and passed a laconic non-speaking order, the matter is remitted to the files of Dispute Resolution Panel for speaking order- GAP International Sourcing India Pvt. Ltd., Versus. Deputy Commissioner of Income Tax - 2010 (12) TMI 94 (Tri)

Non-speaking orders undermine procedural fairness; require issuance of a speaking order addressing side assessee objections. A Dispute Resolution Panel issued a laconic, non speaking order that failed to address a side assessee's objections to a draft assessment order, engaging the requirement for a speaking order that records reasons and specifically deals with the side assessee's submissions.