CESTAT orders without reasons are not sustainable: SC

Commissioner of Customs Vs Lucky Steel Industries (Supreme Court of India)

Supreme Court reviewed the appeal in Commissioner of Customs Vs. Lucky Steel Industries, challenging the order dated April 24, 2018, issued by the Customs, Excise, and Service Tax Appellate Tribunal (CESTAT). The Court found that the Tribunal’s decision lacked detailed reasoning and failed to analyze the necessary legal and factual aspects before reaching a conclusion. As a final fact-finding body, the Tribunal is expected to provide a logical articulation of its conclusions rather than a mere declaration of its decision.

Observing this deficiency, the Supreme Court set aside the Tribunal’s order and remanded the matter for fresh adjudication. The Court clarified that it had not commented on the merits of the case and only emphasized the requirement for a reasoned decision. The Tribunal is now required to reassess the case in accordance with legal principles and ensure a well-reasoned judgment.

This decision aligns with previous rulings emphasizing the importance of reasoned orders in judicial and quasi-judicial proceedings. The Supreme Court has consistently held that appellate bodies must provide a detailed rationale for their conclusions to uphold principles of natural justice.

To expedite proceedings, the Court directed the parties to appear before the Tribunal on December 14, 2022, for the scheduling of the hearing. The Supreme Court also stated that no order as to costs would be made and disposed of any pending applications in connection with the appeal. The remand ensures that the Tribunal properly evaluates the issues before rendering its final decision.

We have heard the learned counsel for the parties and also perused the impugned order dated 24.04.2018 passed in Customs Appeal Nos. 176/2011 and 11917/2017. We find that the impugned order while accepting the appeal of the respondent, is non-reasoned and does not analyse and resonate the issues and contentions required to be answered to decide the appeal. Conclusion is not equivalent to logical articulation required for arriving at the conclusion. The Appellate Tribunal is a final fact-finding body and therefore, should have examined the facts as well as the legal position before pronouncing the final outcome.

In this background, we set aside the impugned order with an order of remit to the Appellate Tribunal to decide the same in accordance with law. We clarify that we have not made any comments on the merit of the case. There would be no order as to costs.

To cut short delay, parties are directed to appear before the bullate Tribunal on 14.12.2022, when the date of hearing would be fixed.

The appeals are disposed of in the aforesaid terms.

Pending application(s), if any, shall stand disposed of.