Reasoned exemption notification adjudication upheld where compliance inquiry showed no legal infirmity despite Revenue's challenge.

Board circulars bind administrative authorities as a matter of administrative discipline, but an adjudication supported by a detailed inquiry into compliance with exemption notification conditions will not be disturbed in Revenue's appeal absent legal infirmity. Here, the adjudicating authority had examined the exporter's fulfilment of the notification requirements through the Development Commissioner's office and passed a detailed, speaking order dropping the demand proceedings. As the record disclosed no error in that decision and the relevant circular had been considered, the Revenue's challenge failed and the dropping of proceedings was sustained.

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Issues: Whether the order dropping the demand proceedings under the exemption notification was liable to be interfered with in Revenue's appeal.

Analysis: The Tribunal noted that Board circulars are binding on administrative authorities as a matter of administrative discipline, but found that the adjudicating authority had made a thorough inquiry into the respondent-exporter's fulfilment of the notification conditions through the Development Commissioner's office. The adjudication order was detailed, speaking and reasoned, and the record did not disclose any legal infirmity in the decision to drop the proceedings.

Conclusion: The Revenue's challenge was rejected and the dropping of proceedings was sustained.

Ratio Decidendi: A reasoned adjudication, supported by inquiry into compliance and not shown to suffer from legal infirmity, will not be interfered with merely because Revenue seeks a different view, especially where the relevant administrative circular has been considered.

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