Tribunal cannot merely record its conclusions without discussing factual matrix, evidence & material

Some general observations have been made by the Tribunal to hold that none of the documents or seized material pertain to the respondent-assessee. These findings, however, do not deal with the observations and findings of the Assessing Officer which are detailed, specific and to the contrary. The Assessing Officer, as noticed above, has referred to several factual aspects, documents, account statements, oral statements etc. in support of the contention of the Revenue.

The Tribunal is required to deal with the factual findings

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