Statutory review procedure governs duty orders; a later contrary communication cannot unsettle a final determination retrospectively.

A statutory authority cannot supersede its own final duty determination by issuing a later contrary communication unless it follows the review procedure expressly provided by law. Where a Commissioner had already passed a final order fixing duty liability under a compounded levy arrangement, a subsequent inconsistent order could not unsettle that position for the relevant period and could operate, if at all, only prospectively. The later order was therefore invalid, and any demand founded on it was unsustainable. The original duty determination remained effective, and the Revenue's challenge failed.

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Issues: Whether the Commissioner could review his earlier order determining duty liability and issue a contrary subsequent order, and whether the consequential demand based on such later order was sustainable.

Analysis: The appellate authority held that once the Commissioner had passed a final order directing payment of duty under the compounded levy arrangement, he could not alter that decision by a later contrary communication. The proper statutory route for altering such an order was under the review mechanism provided by the Act, and absent such review the later order could not override the earlier one. It was further noted that any change, if at all permissible, would operate only prospectively and not retrospectively to unsettle the position already taken for the relevant period.

Conclusion: The later order was invalid, and the demand founded upon it was unsustainable.

Final Conclusion: The Revenue's challenge failed, and the assessee's position on the duty liability as originally determined was upheld.

Ratio Decidendi: A statutory authority cannot review or supersede its own final order except through the procedure expressly provided by law, and a contrary subsequent order without such review is void and cannot sustain a demand for the prior period.

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