ORDER S.R. NAYAK, J. These appeals arise out of the common order passed by the Commissioner of Commercial Taxes, Hyderabad, the first respondent herein. The question that falls for our consideration in both the appeals is common and hence both the appeals were heard together and they are being disposed of by this common order. 2. The precise question that fell for consideration before the appellate authority and the revisional authority is whether the appellant herein has received the very same oil duly refined which was earlier purchased from local registered dealers in the State of Andhra Pradesh and sent to the Refinery situate at Raichur. The answer to this question determines the sales tax liability of the appellant. We have perused the order of the appellate authority and the order of the first respondent. The appellate authority on consideration of the relevant documents such as purchase bills, way bills, lorry receipts, delivery notes, packing slips and GP-1 gate passes for removal of excisable goods from the refinery as required under the provisions of the Central Excise Act, and on consideration of two concrete transactions as examples came to the conclusion that the continuity is not broken and separate identity of supply and receipt of the oil is maintained and the view taken by the assessing authority to the contrary is untenable. The Commissioner in his order, after referring to the way bills, has generally observed that the way bills themselves are not the proof to show that the very same oil which was purchased in the State of Andhra Pradesh and sent to Raichur for refining was refined and sent back to Hyderabad. Quite curiously the Commissioner has stated in his order that the appellant has not produced any record except way bills to show that the receipts, processing and dispatch of oil in the two refineries was being maintained separately and that at no point of time the oil sent from Hyderabad got mixed with other oil. When the Commissioner has chosen to record the above finding, he has not disclosed materials/documents in support of the said finding. Therefore, we hold that the above finding recorded by the Commissioner is not based on any discernible evidence and material. In other words, the finding recorded by the Commissioner in the fact situation of the case should be held to be perverse. Therefore, we hold that the above finding recorded by the Commissioner is not based on any discernible evidence and material. In other words, the finding recorded by the Commissioner in the fact situation of the case should be held to be perverse. The impugned order of the Commissioner is not a speaking order. 3. In our considered opinion, having regard to the specific direction earlier given by the Sales Tax Appellate Tribunal by its order dated May 25, 1987 the appellate authority as well as the revisional authority ought to have considered all the relevant documents relating to every oil transaction from Andhra Pradesh State to Raichur refinery and back during the assessment years 1980-81 and 1981-82 and recorded the finding whether the same oil which was purchased in the State of Andhra Pradesh and which was sent to Raichur refinery was brought back to the State of Andhra Pradesh after refinement. Unfortunately, the appellate authority as well as the revisional authority have not applied their mind to this specific question except generally recording divergent finding without disclosing supporting materials and evidence. In that view of the matter, we think it appropriate to remit the matter to the appellate authority, i.e., the Appellate Deputy Commissioner (CT), Secunderabad Division, for redetermining the tax liability of the appellant-assessee by a reasoned order and after consideration of all relevant documents and evidence. 4. In the result, we allow the special appeals, and the order under appeal is set aside. The proceedings now shall stand remitted to the first appellate authority, i.e., the Appellate Deputy Commissioner (CT), Secunderabad Division with a direction to determine the tax liability of the appellant de novo by considering all the relevant documents and materials placed before him by the appellant-assessee and in the light of this judgment and the directions of the Tribunal dated May 25, 1987. No costs. Appeals allowed.