JUDGMENT Ranjan Gogoi, J. 1. This appeal under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as the Act), is directed against the order dated September 7, 2005, passed by the Income Tax Appellate Tribunal, Gauhati Bench, Guwahati. By the aforesaid order the learned Tribunal has affirmed the earlier order dated November 21, 2003, passed by the Commissioner of Income Tax (Appeals-2) by which the rectification in the assessment of the respondent-company for the assessment year 1999-2000, as made by the Assessing Officer, has been cancelled. 2. The facts, which are short and are not in dispute. 3. In exercise of the powers under Section 154 of the Income Tax Act (hereinafter referred to as the Act) in respect of the assessment year 1999-2000, the Assessing Officer had rectified the assessment of the respondent-company by addition of an amount of Rs. 1,27,45,138 received by the respondent-company on account of transport subsidy. Aggrieved by the aforesaid rectification, the respondent-company had moved the Commissioner of Income Tax (Appeals-2). Before the said authority the question that arose is whether transport subsidy received by the respondent-company was in the nature of a capital subsidy or a revenue receipt so as to determine the liability of the said amount to suffer tax. The learned Commissioner (Appeals), after reciting the rival contentions, disposed of the appeal by a cryptic order dated November 21, 2003, which is to the following effect: Accordingly, accept the submission of the appellant and cancel the order of rectification passed by the Assessing Officer, in that event there is no necessity to consider the rest of the grounds. The appeal is allowed. 4. The Revenue, being aggrieved, preferred a further appeal before the learned Tribunal. Once again, the learned Tribunal elaborately recited the cases of the respective parties and thereafter came to the following conclusion: 9. We have examined the rival submissions. We find no infirmity in the order of the Commissioner of Income Tax (Appeals) which is confirmed. "10. In the result, the appeal filed by the Revenue is dismissed. 5. We have gone through the grounds of appeal as well as the substantial questions of law framed in the present appeal. We have examined the rival submissions. We find no infirmity in the order of the Commissioner of Income Tax (Appeals) which is confirmed. "10. In the result, the appeal filed by the Revenue is dismissed. 5. We have gone through the grounds of appeal as well as the substantial questions of law framed in the present appeal. In our considered view, having regard to the conclusions recorded by the learned Tribunal in paragraphs 9 and 10 of the order dated September 7, 2005, the following additional substantial question of law does arise in the present case: Whether the order dated September 7, 2005, passed by the learned Tribunal without disclosing any reasons for the conclusion reached, is a valid order in the eye of law? 6. The Tribunal is a quasi-judicial body and is the last fact finding authority under the provisions of the Act. Appeals against orders passed by the Tribunal can be filed in High Court under Section 260A of the Act provided substantial questions of law arise from such orders. In the present case the order dated September 7, 2005, merely recites the conclusion that the learned Tribunal had thought it fit to arrive at without disclosing any reason(s) therefore or even the manner in which the decision was arrived at. Time and again it has been emphasized that reasons are the live-link between the basic facts of a case and the conclusion reached and every judicial order must disclose the manner in which the mind has been applied to reach the conclusion recorded. Unfortunately, in the present case the order of the learned Tribunal does not satisfy even the bare necessities of an order of a quasi-judicial authority. 7. An argument has been advanced by Dr. A.K. Saraf, learned Counsel for the respondent that as the learned Tribunal had merely affirmed the order of the first appellate authority, the learned Tribunal was not required to give any reason(s). We do not agree with the aforesaid argument. Even in a situation where the first appellate authority affirms the finding of the primary authority, a minimum reasoning has to be disclosed though in such cases an elaborate discussion of the various issues need not be recorded, as the same already exists in the order of the primary authority. We do not agree with the aforesaid argument. Even in a situation where the first appellate authority affirms the finding of the primary authority, a minimum reasoning has to be disclosed though in such cases an elaborate discussion of the various issues need not be recorded, as the same already exists in the order of the primary authority. In the present case when the order of the Commissioner (Appeals) itself was a highly cryptic order, the same could not have been affirmed by the learned Tribunal in the manner done. 8. We, therefore, have no hesitation to set aside the order dated September 7, 2005, passed by the learned Tribunal and to remand the matter to the learned Tribunal for a de novo consideration in accordance with law and the directions set out herein above. We, therefore, allow the appeal to the extent indicated above.