Quasi-judicial excise registration decisions are not appealable to the Commissioner (Appeals) when jurisdiction is absent.

Under the central excise registration framework, a common registration request required the proper officer to assess the application case by case, hear the applicant, and decide whether two premises formed part of the same factory. Because that exercise involved evaluation of relevant material and interlinked manufacturing processes, it was treated as quasi-judicial in nature. On that basis, the resulting decision on the registration request was not regarded as appealable to the Commissioner (Appeals), and the Commissioner (Appeals) was held to lack jurisdiction to direct further action on that decision.

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Issues: Whether the Commissioner's decision on an application for common registration under the central excise regime was quasi-judicial in character and whether the appeal lay to the Commissioner (Appeals).

Analysis: Section 6 of the Central Excise Act and Rule 9 of the Central Excise Rules, 2002 govern registration under the excise law. The Board's instructions on common registration required the Commissioner to examine the application case by case, consider multiple relevant factors, hear the applicant, and decide whether two premises formed part of the same factory. That decision involved evaluation of relevant material and determination of interlinked manufacturing processes, which gave the exercise the character of a quasi-judicial process. The order communicated to the respondent through the Deputy Commissioner was therefore treated as the Commissioner's decision on the registration request. In that view, the Commissioner (Appeals) had no jurisdiction to treat the matter as one requiring further direction to the Commissioner or to assume appellate jurisdiction over that decision.

Conclusion: The decision on the registration application was quasi-judicial in nature and was not appealable to the Commissioner (Appeals); the Department's objection succeeded.

Final Conclusion: The impugned appellate order was set aside and the Department's appeal was allowed.

Ratio Decidendi: Where the statutory registration process requires the proper officer to evaluate relevant factors case by case and decide the application after hearing the applicant, the resulting decision is quasi-judicial and is not amenable to appeal before an authority lacking jurisdiction over that decision.

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