Refund denial required fresh verification and hearing before reconsideration of the claim on the merits.

Denial of a refund claim for special additional duty could not be sustained where the claim was rejected for want of a Chartered Accountant's certificate and the appellate stage proceeded without further hearing. The record indicated that the taxpayer asserted filing the relevant documents, so the dispute required fresh verification of the supporting materials and reconsideration on the merits. The matter was remitted to the original authority for de novo examination with a reasonable opportunity to produce the certificate and other documents, followed by a reasoned order.

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Issues: Whether the denial of refund claim required remand for fresh consideration after affording reasonable opportunity of hearing and verification of supporting documents.

Analysis: The refund claim for special additional duty was rejected for non-filing of the Chartered Accountant's certificate, while the appellate authority also proceeded without granting further opportunity of hearing. The record indicated that the appellant claimed to have filed the relevant documents, and the dispute required reconsideration by the original authority after permitting production of the certificate and other supporting materials. A fresh decision was therefore necessary on the basis of proper verification and a reasoned order.

Conclusion: The matter was remitted to the original authority for de novo consideration after affording a reasonable opportunity to the appellant.

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