Reasoned revisional orders are required when rejecting excise duty rebate claims on exported goods; bare reference to general rules is insufficient.

A revisional authority cannot reverse a reasoned order on rebate of excise duty for exported goods by relying only on a general bar in the excise manual. Where the Commissioner had found that the drawback claim related only to the customs component and not to central excise duty, the revisional order had to address that reasoning, the drawback notification, and the distinction between customs drawback and excise component drawback. A mere recital of statutory text and general interpretive principles was insufficient. The revisional order was set aside, and the matter was remanded for fresh, reasoned consideration in accordance with law.

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Issues: Whether the revisional order rejecting rebate of excise duty on inputs used in exported goods could be sustained when it failed to deal with the Commissioner's findings and the applicability of the duty drawback notification and scheme.

Analysis: The revisional authority set aside the Commissioner's order by a brief reiteration of the general bar contained in the excise manual, without examining the Commissioner's reasoning that the drawback claimed related only to the customs component and not to central excise duty. The order did not record any finding as to why the Commissioner's view was incorrect, nor did it engage with the notification governing drawback rates or the distinction between customs drawback and excise component drawback. A revisional order that reverses a reasoned order must itself disclose reasons and address the issues raised; a mere reference to the statutory text and general principles of interpretation is insufficient.

Conclusion: The revisional order could not be sustained and was set aside. The matter was remanded to the Central Government for fresh consideration and a reasoned decision in accordance with law.

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