Natural justice breach in revision proceedings led to remand for fresh hearing after denial of reasonable opportunity.

A revision order passed under Section 84 of the Finance Act, 1994 was set aside because it was issued without granting a reasonable opportunity of hearing, amounting to breach of natural justice. The matter was remanded to the Commissioner for fresh adjudication after giving the appellant such opportunity. The separate contention that the original order survived the appellate order was not finally decided and was left open on remand.

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Issues: Whether the revision order passed under Section 84 of the Finance Act, 1994 was liable to be set aside for want of reasonable opportunity of hearing and breach of natural justice.

Analysis: The revision order was passed without granting a reasonable opportunity of hearing. This amounted to a violation of the principles of natural justice. The challenge based on the alleged survival of the original order after the appellate order was not finally decided and was left open on remand.

Conclusion: The impugned revision order was set aside and the matter was remanded to the Commissioner for fresh after giving reasonable opportunity of hearing to the appellant.

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