Amnesty benefit revocation and appropriation of remittances require fresh hearing before coercive recovery continues.

The dispute concerned whether earlier remittances under an amnesty arrangement should be credited towards principal liability rather than appropriated first towards interest under revenue recovery provisions. Because the proposed revocation of amnesty benefit was not shown to have been conclusively finalised with clear service and hearing, the assessee was entitled to place detailed objections before the authority. The authority was directed to reconsider the matter afresh in accordance with law after hearing the assessee, and coercive recovery steps were kept in abeyance meanwhile.

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Issues: Whether the petitioner was entitled to a fresh opportunity to object to the notice proposing revocation of amnesty benefit and to have the liability re-examined in relation to the manner of appropriation of amounts already remitted.

Analysis: The dispute centred on the appropriateness of adjusting earlier remittances towards interest under the revenue recovery provisions instead of giving credit towards the principal liability under the amnesty arrangement. The notice proposing revocation of the amnesty benefit was not shown to have been conclusively acted upon with clarity as to service, hearing, and finalization. In these circumstances, and having regard to the need to consider the factual and legal objections in the light of the amnesty scheme and the earlier decision relied on, the Court found it to grant the petitioner an opportunity to submit detailed objections and required the authority to consider them afresh after hearing the petitioner.

Conclusion: The petitioner was granted an opportunity to file objections to Ext.P14, the authority was directed to consider them in accordance with law, and coercive steps were kept in abeyance meanwhile.

Ratio Decidendi: Where the finalization of recovery or revocation under an amnesty scheme is not shown to have been completed with clear service and hearing, the affected assessee may be afforded a fresh opportunity before coercive recovery is continued.

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