Apparent error in excise duty quantification justified remand for fresh consideration of the taxpayer's objections.

An apparent factual error in the calculation of excise duty justified fresh examination of the petitioner's liability, as the record showed confusion in the value of goods cleared and the resulting duty quantification. The High Court set aside the order rejecting correction and reconsideration, and remitted the matter for fresh consideration of the petitioner's objections after hearing the parties in accordance with law. It declined to decide the broader question whether completed settlement proceedings could be reopened, leaving that substantive controversy open while ensuring reconsideration on the existing record.

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Issues: Whether the order rejecting the petitioner's application for correction of the duty liability and refusing reconsideration of the settlement could be set aside in view of the apparent mistake in the calculation of excise duty.

Analysis: The record disclosed a confusion in the calculation of the value of the goods cleared and, consequently, in the quantification of the duty liability. In those circumstances, the matter required a fresh examination rather than rejection on a technical ground. Without deciding the larger question whether the completed settlement proceedings could be reopened, the Court found it appropriate to direct reconsideration of the entire issue, particularly since the respondents' own affidavit indicated that the relevant factual aspects had not been properly brought before the authority earlier.

Conclusion: The impugned order was set aside and the matter was remitted to the authority for fresh consideration of the petitioner's objections after giving an opportunity of hearing, in accordance with law.

Final Conclusion: The writ petition succeeded to the extent of securing a remand for reconsideration of the petitioner's liability and objections, while the substantive controversy on reopening was left undecided.

Ratio Decidendi: Where the quantification of tax liability appears to involve an evident factual error or confusion, the matter may be remitted for fresh decision after hearing the affected party, without deciding broader questions unnecessarily.

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