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Issues: Whether the revisional authority could stay the appellate order and set aside the unblocking of input tax credit without first calling for and examining the record, without independent application of mind, and without complying with the statutory procedure and principles of natural justice.
Analysis: The revisional power under the GST law is conditional and supervisory in nature. It can be exercised only when the authority forms a view, on the basis of the record, that the subordinate order is erroneous and prejudicial to the interest of revenue. The record showed that the impugned stay was made on the basis of subordinate noting and a proposal, without the record of the appeal being called for and examined. The notice issued in support of revision did not reflect the statutory grounds, and no meaningful opportunity preceded the stay order. A quasi-judicial order affecting civil consequences must be reasoned, and where the statute does not exclude it, fair hearing and observance of natural justice are required.
Conclusion: The revisional order was invalid for failure to follow the statutory preconditions and for breach of natural justice. The impugned order could not be sustained.
Final Conclusion: The writ petition succeeded and the petitioner obtained relief against the revisional interference with the appellate order.
Ratio Decidendi: Revisional jurisdiction under the GST framework can be exercised only after the authority calls for and examines the relevant record and records a reasoned satisfaction that the subordinate order is erroneous and prejudicial to revenue; such power cannot be validly exercised on the basis of a subordinate recommendation alone or without affording due hearing where civil consequences follow.