Natural justice limits automatic binding rulings where affected dealers were not heard or served, so wider effect was stayed.

The amended Section 59(5) of the U.P. Value Added Tax Act, 2008 was stayed at the interim stage because its effect of making the Commissioner's ruling binding on all assessing and appellate authorities, without hearing or serving other affected dealers, raised a prima facie issue of natural justice and arbitrariness. The Commissioner's order was therefore treated as binding only on the applicant who sought the ruling, not on other dealers or authorities. The petitioner was left free to contest the goods classification before the assessing authority, while the wider binding effect of the amendment remained restrained.

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Issues: Whether the amended sub-section (5) of Section 59 of the U.P. Value Added Tax Act, 2008, making the Commissioner's order binding on all assessing and appellate authorities, should be stayed at the interim stage.

Analysis: The writ petition challenged the amendment as arbitrary and violative of constitutional guarantees because only the applicant before the Commissioner is heard and supplied the order, while other affected dealers and authorities are bound without being heard or served. Prima facie, the arrangement raised serious concerns of unequal treatment and breach of natural justice. The interim grievance also related to the provisional assessment being influenced by the Commissioner's order, though the assessment authority had recorded independent reasons.

Conclusion: The operation of the amended sub-section (5) of Section 59 was stayed. The Commissioner's order under Section 59(1) was directed to bind only the applicant who sought the ruling and not all assessing or appellate authorities in relation to other dealers.

Final Conclusion: Interim relief was granted by restraining the wider binding effect of the amendment, while leaving the petitioner free to contest the classification of the goods before the assessing authority.

Ratio Decidendi: Where an administrative determination affects persons who were not heard and to whom the order was not communicated, its automatic binding effect on all affected authorities and dealers raises a prima facie issue of natural justice and arbitrariness.

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