Refund direction held inconsistent where bank payment and credit ledger treatment conflicted; reconsideration ordered after hearing.

A refund sanction order was found to be internally inconsistent because it directed payment to the petitioner's bank account while the detailed order also required credit to the registered taxpayer's credit ledger. Given the closure of business, cancellation of registration, and the absence of any tax due and payable, the direction was treated as requiring reconsideration by the proper officer. The officer was directed to re-examine the refund direction after giving the petitioners an opportunity of hearing, and to do so within six weeks.

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Issues: Whether the refund sanctioned to the petitioner was required to be paid to the petitioner's bank account or credited to the registered taxpayer's credit ledger, and whether the proper officer should reconsider the direction in the refund sanction order.

Analysis: The refund application followed an appellate order allowing the petitioners' claim. The refund sanction order allowed the refund amount and directed payment to the bank account, but the detailed order contained a direction to credit the amount to the petitioner's credit ledger. In view of the closure of business, cancellation of registration, and the absence of any tax due and payable, the direction was found to be self-contradictory and required reconsideration by the proper officer. The reconsideration was directed to be undertaken after giving the petitioners an opportunity of hearing.

Outcome: The proper officer was directed to reconsider the refund direction within six weeks after hearing the petitioners.

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