JUDGMENT U. L. BHAT, C.J. - The following questions have been referred to this Court by the Board of Revenue at the instance of the assessee : "(1) Whether, on the facts and circumstances of the case, the Tribunal was justified in holding that elaboration by Deputy Commissioner of the point cited in one line for rejection of accounts by assessing authority and the detailed examination of papers, was in order ? (2) Whether, on the facts and circumstances of the case, the Tribunal was justified in holding that the assessee was not entitled to set-off under section 8(1)(a) of the M.P. General Sales Tax Act, 1958, on tax-paid goods, used as raw material by him in manufacture of goods as job-work for sale by other registered dealers ?" 2. Assessee is not represented before us. We have heard learned counsel for the Revenue. 3. The assessee is engaged in the business of cotton ginning and pressing. He main establishment is in Udaigarh and he has a branch in the name and style of M/s. Visheshwar Dayal Vasudev in Bamania. The relevant period of assessment is from April 1, 1979 to March 31, 1980. The Assistant Sales Tax Officer rejected the turnover as disclosed in the books of account on account of non-maintenance of complete manufacturing account and also because there was unexplained difference between the returns submitted and the turnover as disclosed by books. The assessee claimed set-off in respect of the raw material used in manufacture of goods on behalf of other registered dealers. This was disallowed on the ground that the assessee had done only job-work and had not purchased raw material nor sold the finished goods. The assessee's appeal was dismissed by the Appellate Deputy Commissioner. Further appeal before the Tribunal was also rejected. 4. One of the questions is whether the first appellate authority could enter into elaborate discussion of any aspect decided in a summary manner by the assessing authority. We fail to see how this raises a question of law and why the Tribunal should have referred this question. It is the duty of the first appellate authority to consider a matter placed before it in all its aspects. This is all the more so when the assessing authority had failed to consider the matter in detail or in a proper manner. It is the duty of the first appellate authority to consider a matter placed before it in all its aspects. This is all the more so when the assessing authority had failed to consider the matter in detail or in a proper manner. The Tribunal was, therefore, correct in holding that the first appellate authority could conduct a detailed examination of any aspect dealt summary or briefly by the assessing authority. 5. The next question relates to plea of set-off put forward by the assessee. The finding of fact is that set-off is claimed in respect of tax paid on raw materials which were converted into manufactured goods by assessee and that the assessee did not purchase the raw materials and did not sell the finished goods but was only doing a job-work. It is also the finding of fact that the raw materials belonged to other registered dealers and the finished products also belonged to them. It was in these circumstances that the statutory authorities and the Appellate Tribunal rejected the plea of such set-off which arises under section 8(1)(a) of the M.P. General Sales Tax Act, 1958 and rule 20-C(1)(a)(iii) of the 1959 Rules. 6. Section 8 deals with set-off or refund of tax in respect of tax-paid goods in certain circumstances. The set-off is to be granted to registered dealers. Clause (1)(a) reads thus : "(1) ............. 6. Section 8 deals with set-off or refund of tax in respect of tax-paid goods in certain circumstances. The set-off is to be granted to registered dealers. Clause (1)(a) reads thus : "(1) ............. (a) When a registered dealer has purchased tax-paid raw material other than tendu leaves and whole pulses or incidental goods which have borne tax under sub-section of section 6 at the full rate exceeding 3 1/2 per cent (that is 3 per cent basic tax and 1/2 per cent additional tax) or 4 1/2 per cent (that is 4 per cent basic tax and 1/2 per cent additional tax) respectively or exceeding such other rate as may be notified by the State Government in respect of any raw material or incidental goods and has consumed or used such raw material or incidental goods in manufacture of or in the mining of any goods specified in Schedule II which have not been declared tax-free under section 12, he shall be entitled to a set-off at a rate equal to the difference between the full rate of tax on such raw material or incidental goods under sub-section (1) of section 6 and the concessional rate of 3 1/2 per cent (that is 3 per cent basic tax and 1/2 per cent additional tax) or 4 1/2 per cent (that is 4 per cent basic tax and 1/2 per cent additional tax) or such other reduced rate aforesaid, as the case may be, in such manner and on such proportion of the price at which such goods were purchased from a registered dealer, as may be prescribed." 7. In order to be entitled to set-off a registered dealer should have purchased tax-paid raw material and must have consumed or used such raw materials in manufacture of any goods specified in Schedule II. 8. Rule 20-C deals with grant of set-off under section 8. The rule prescribes restrictions and conditions for grant of set-off. Condition No. (iii) reads thus : "20-C(1)(a)(iii) - The goods manufactured by using the tax-paid raw material or the tax-paid incidental goods should have been sold by the registered dealer in the State of Madhya Pradesh or in the course of inter-State trade or commerce or in the course of export out of the territory of India;" The rule makes it clear that the manufactured goods must belong to registered dealer who claims set-off. The condition is that he should sell the same in the State of M.P. or in the course of inter-State trade or commerce or in the course of export out of territory of India. 9. On the finding of fact that the raw materials were not purchased by the assessee and the manufactured goods did not belong to him and he did only a job-work on the raw materials belonging to another registered dealer it necessarily follows that he is not entitled to the set-off claimed by him. The second question referred should also be answered against the assessee. 10. Both the question are answered in the affirmative, i.e., in favour of the Revenue and against the assessee. A copy of this order under the signature of the Additional Registrar and seal of the High Court shall be forwarded to the Tribunal. Reference answered in the affirmative.