CESTAT quashes order as it lacked reasoning or findings to support its conclusion

CESTAT observed that impugned order has been issued in a highly unusual manner, lacking any reasoning or findings to support its conclusion. Although the order appears detailed, it primarily consists of recording the submissions made by the assesses and the revenue, with a brief two-line conclusion stating that the order is set aside with consequential relief as per law, and the appeal is allowed. This violates the fundamental principle that justice must not only be done but also seen to be done. The assessee’s appeal was granted through a non-speaking order, and the entire adjudication order was set aside based on a single decision of the Hon’ble Karnataka High Court, which seems to be limited to the issue of interest liability. The learned Commissioner should have addressed the appellant’s contentions and thoroughly examined each finding and reasoning presented in the original order before setting it aside. Consequently, we are compelled to overturn the impugned order and remand the matter back to the learned Commissioner (Appeals) for a fresh and fair consideration of the case based on its own merits. This process should include providing a reasonable opportunity for both sides to be heard and providing proper reasoning and findings when arriving at any conclusion in the appellant’s appeal.