Release of protest deposits requires a reasoned departmental decision, with the petitioner's contentions kept open.

Amounts deposited under protest could not be treated as finally retained without departmental consideration of the request for release. The Department was directed to hear the petitioner and pass a reasoned decision on the claim within two weeks, with all contentions kept open.

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Issues: Whether the revenue could retain the amounts deposited under protest, and whether the petitioner's request for release of such amounts required consideration by the departmental authority.

Outcome: The matter was directed to be heard by the Department, which was to take an appropriate reasoned decision on the petitioner's contentions within two weeks, with all contentions kept open.

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