Natural justice in valuation inquiries requires the same officer to hear and decide; split hearing and report process was invalid.

A special valuation branch inquiry under Circular No. 5/2016 was treated as a quasi-judicial process requiring the officer to call for information, allow the importer to present evidence, and issue a reasoned report on declared value. Because the personal hearing formed an integral part of that decision-making process, the same authority was expected to hear the importer and decide the matter. A procedure in which one officer conducted the hearing and another furnished the investigation report was found to breach natural justice, and the absence of separately proved prejudice did not cure the defect. The investigation report was quashed and the matter remitted for a fresh hearing and report.

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Issues: Whether the investigation report issued under the special valuation branch procedure was liable to be quashed for breach of natural justice because the personal hearing was conducted by one officer and the report was furnished by another.

Analysis: The special valuation branch inquiry under Circular No. 5/2016 required the officer to call for information, afford a suitable opportunity to the importer to adduce evidence, and then furnish an investigation report containing findings and reasons for acceptance or rejection of the declared value. That function was treated as quasi-judicial, not merely administrative or institutional. In such a framework, the personal hearing formed an integral part of the decision-making process, and the hearing officer was expected to apply the mind to the submissions and materials before finalising the report. The procedure where one officer heard the importer and another later issued the investigation report was held to offend the basic principle that justice must not only be done but must also appear to be done. The absence of a separately shown prejudice did not save the procedure once the breach of natural justice was established.

Conclusion: The investigation report was quashed, and the matter was sent back for a fresh personal hearing and a fresh investigation report by the concerned authority.

Ratio Decidendi: Where a statutory or circular-based inquiry requires a personal hearing as part of a quasi-judicial determination, the same authority must ordinarily hear and decide the matter; a hearing by one officer followed by a report by another violates natural justice.

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