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Issues: Whether directions issued by the Central Board of Revenue could control the quasi-judicial discretion of the Collector and the Central Government in classifying the goods for excise purposes, and whether the impugned orders were vitiated by reliance on such directions.
Analysis: The classification dispute was one that had to be decided by the statutory authorities on their own judgment. The appellate and revisional functions exercised under the Act were quasi-judicial in character, and such authorities could not be bound by administrative directions issued by a superior executive body. A direction purporting to decide the very issue in dispute would fetter independent adjudication and undermine the requirement of impartial decision-making. The record showed that the Collector and the Government treated the Board's direction as decisive, and the proceedings were therefore tainted. The Court also held that the incorrect assumption regarding chemical examination could not sustain the orders, and the matter could not be finally decided by this Court on the available material.
Conclusion: The Board's direction was invalid insofar as it controlled the quasi-judicial decision-making of the Collector and the Central Government, and the impugned orders were vitiated.
Ratio Decidendi: Administrative instructions cannot control or fetter the independent judgment of a quasi-judicial authority deciding a statutory dispute; any decision founded on such extraneous direction is vitiated.