Final quasi-judicial determination bars a fresh show cause notice on the same import transaction and facts.

A fresh show cause notice cannot be sustained on the same import transaction once a competent quasi-judicial authority has finally decided the legality of that import in favour of the importer. The earlier appellate finding that the importation complied with the import licence had attained finality, and that final determination barred another authority from reopening identical facts or reaching a contrary conclusion. Allowing a second notice on the same transaction would undermine finality and generate conflicting quasi-judicial findings. The show cause notice was therefore liable to be quashed.

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Issues: Whether the impugned show cause notice could be sustained when the same import transaction had already been finally decided in favour of the petitioners by the appellate tribunal.

Analysis: The earlier appellate decision had conclusively held that the importation was in accordance with the import licence, and that decision had attained finality. Once a quasi-judicial authority has finally determined the legality of the same importation, it is not open to another authority to issue a fresh show cause notice on the same facts and seek to record a contrary finding. Permitting such a course would destroy finality and create conflicting decisions on the same matter.

Conclusion: The show cause notice was unsustainable and liable to be quashed.

Ratio Decidendi: A matter finally decided by a competent quasi-judicial authority on the same facts cannot be reopened by issuing a contrary show cause notice on the same transaction.

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