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Issues: Whether the show cause notice and consequent proceedings were without jurisdiction, and whether the matter should be remanded for fresh consideration.
Analysis: The objection to jurisdiction was raised as a question of law and required examination. The notice did not indicate the bill of entry number, and the bill of entry placed on record showed filing at Kandla. The earlier factual pleas were also not fully appreciated by the adjudicating authority, and the appellants were entitled to place their evidence before the jurisdictional Commissioner.
Conclusion: The jurisdictional objection was directed to be examined by the Commissioner on remand, and the proceedings were sent back for fresh adjudication after giving the appellants an opportunity to substantiate their case.