Natural justice in exemption claims: rejection without hearing is invalid, and later corrected eligibility records may justify fresh consideration.

Where a notification conditions rejection of an exemption application on affording a reasonable opportunity of hearing, refusal without notice or show-cause opportunity is procedurally invalid and cannot stand. The later corrected certificate, confirming the relevant production date within the notified period, could be considered because the delay arose from administrative process rather than the applicant's fault; the exemption claim therefore required fresh reconsideration in light of the corrected record. The availability of an alternative statutory remedy did not bar writ relief where the petition had already been entertained and affidavits exchanged. The impugned rejection was quashed and the authority was directed to decide the application afresh in accordance with law.

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Issues: (i) Whether the rejection of the exemption-certificate application without notice and opportunity of hearing was sustainable under Clause 19 of the notification; (ii) Whether the later issuance of the corrected certificate and the surrounding circumstances entitled the applicant to reconsideration of the exemption claim; (iii) Whether the writ petition should be rejected on the ground of alternative statutory remedy.

Issue (i): Whether the rejection of the exemption-certificate application without notice and opportunity of hearing was sustainable under Clause 19 of the notification.

Analysis: Clause 19 required rejection of an exemption application only after giving the applicant a reasonable opportunity of being heard. The record showed that no notice or show-cause opportunity was given by the authority that passed the impugned order. The application was rejected on the same day on which the petitioner had informed the authority that the corrected certificate was awaited. The procedural safeguard built into the notification was therefore not followed.

Conclusion: The rejection order was vitiated for breach of the requirement of hearing and could not be sustained.

Issue (ii): Whether the later issuance of the corrected certificate and the surrounding circumstances entitled the applicant to reconsideration of the exemption claim.

Analysis: The corrected certificate issued by the Director of Industries confirmed the relevant date of production within the notified period for exemption. The delay in correction was attributable to the administrative process and not to the applicant. Subsequent events having material bearing on the controversy could be taken into account to do justice, and the applicant should not lose the benefit of the notification because of a bureaucratic delay beyond its control.

Conclusion: The application had to be reconsidered afresh in light of the corrected certificate and the notified eligibility period.

Issue (iii): Whether the writ petition should be rejected on the ground of alternative statutory remedy.

Analysis: Although an alternative revision was referred to, the writ petition had already been entertained at the admission stage and affidavits had been exchanged. In such circumstances, it was not appropriate to refuse relief merely on the ground of alternative remedy.

Conclusion: The preliminary objection based on alternative remedy was rejected.

Final Conclusion: The impugned rejection of the exemption application was quashed, and the authority was directed to decide the application afresh in accordance with law.

Ratio Decidendi: Where a notification itself conditions rejection of a tax-exemption application on affording a reasonable opportunity of hearing, an order passed without such hearing is invalid, and subsequent material events showing eligibility may be considered to prevent denial of relief on purely technical grounds.

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