ORDER (Per R. Gururajan, J.) This Petition is directed against the order of the Karnataka Appellate Tribunal dated 21.2.1997. Respondent is a dealer engaged in the activity of manufacturing extraction of Edible Oil from Oil Seeds such as groundnut. For the Assessment Year 1988-89, the Assessment was concluded under Section 12(7) of the Act on 25.4.1996. The Assessing Authority having found that there was escapement of turnover liable to tax, re-opened the Assessment and proceeded to pass an Order of Re-assessment dated 21.2.1997. The Assessee preferred an Appeal against the Re-assessment Order. The said Appeal was allowed in part. A Second Appeal was filed before the Appellate Tribunal. The Tribunal allowed the Appeal in part by an order dated 27.12.2002. Aggrieved by the said order, State is before us by raising the following questions of law. "1. Whether the Tribunal is not bound to give a finding of fact in allowing the Appeals on a disputed questions of fact held against the Assessee by the Assessing Authority in allowing the Appeal with relation to such a disputed fact ? 2. Whether the Tribunal was justified in negating the authentic information gathered by a Statutory Authority and a department of the Government in respect of the Assessee's business transactions (which were relevant for the purpose of Assessment under the Karnataka Sales Tax Act, 1957) notwithstanding that the action initiated by the concerned Authority under such other enactment was dropped ?" Heard the learned Counsel for the parties and perused the material on record. Smt. Sujatha, learned Government Advocate says that the impugned order is a clear case of non-application of mind. She says that there is absolutely no discussion forthcoming in the case on hand in terms of the order of the Appellate Tribunal. Therefore she says that the Tribunal is wrong in passing an order in favour of the Assessee. Per contra, Sri Indra Kumar, learned Counsel would argue that the Principal Sessions Judge has chosen to pass an order ordering acquittal and in that view of the matter, according to the learned Counsel, the impugned order has to be sustained in the given circumstances. After hearing, we have carefully perused the material on record. From the material on record, what is clear to us is that the Respondent - Assessee was subjected to tax on the ground of escapement of turnover in the case on hand. After hearing, we have carefully perused the material on record. From the material on record, what is clear to us is that the Respondent - Assessee was subjected to tax on the ground of escapement of turnover in the case on hand. An adverse order was passed and in Appeal the said order was set aside in part. In Second Appeal, the Tribunal has chosen to delete the additions made by the Authorities. Penalty was also set aside. Let us see as to whether the said order is sustainable or not. From the material on record it is seen that the Tribunal has chosen to frame as many as seven issues in para 8 of the order. It has chosen to give a finding in respect of all the issues in the impugned order. Issues 2, 3 and 6 assume importance and they go to the root of the matter. While answering the said issues, the Tribunal in our view without applying is mind has chosen to set aside the findings of the Assessing Authority and also the Appellate Authority as without discussion. Insofar as the Acquittal Order as pressed is concerned, it is seen that the acquittal in favour of Assessee is under Section 232 of the Cr. P.C. in terms of the order of the learned Judge. Learned Judge has chosen to say that the Prosecution has failed to prove the guilt of the accused beyond reasonable doubt. It is not a clean acquittal. Even otherwise, in our view, a mere acquittal by itself does not wipe out the liability of tax as sought to be argued by the Respondent. Acquittal Order, at the most, may be a piece of evidence for the purpose of consideration of case on merits. Law is also well-settled that power and jurisdiction are totally different with regard to a proceeding by the Tax Authority and with regard to a proceeding before a Criminal Court. In these circumstances, we are not prepared to accept the argument that on the basis of the mere Acquittal Order, the Tribunal Order has to be accepted as argued before us. In the result, this revision is accepted. The order of the Tribunal is set aside. The first question is answered in favour of the Revenue. The Second question is not answered in the light of the remand. In the result, this revision is accepted. The order of the Tribunal is set aside. The first question is answered in favour of the Revenue. The Second question is not answered in the light of the remand. Parties are directed to appear before the Tribunal without waiting for any notice on 17.7.2006. The Tribunal is directed to complete the proceedings on or before 31.12.2006 without in any way being influenced by the earlier order or by this order. Ordered accordingly. No costs.