The Commissioner (Appeals) dismissed the assessee’s grounds relating to disallowance under section 40(a)(i) without discussing the applicability of the Double Taxation Avoidance Agreement or sections 9 and 195. The Tribunal held that section 250(6) mandates a reasoned and speaking order. The non-speaking order violated the principles of natural justice and the matter was restored to the Commissioner (Appeals) for fresh adjudication. (AY. 2017-18 & 2018-19).