Appellate authority's inconsistent approach in accepting/rejecting contentions sans evidence rejected. Order quashed, remanded for judicial consideration.

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....Appellate Authority affirmed impugned order without evidence regarding petitioner's intention to evade tax. Inconsistent approach rejecting petitioner's contention for lack of evidence while accepting department's contention despite absence of evidence. Appellate Authority must act judicially, adopting same approach towards assessee and department. Order quashed, petition allowed by way of remand.....