Procedural fairness and fresh evidence require remand for reconsideration of TRAN credit rejections, permitting Authority to reassess supporting records.

Petition concerns rejection of TRAN credits where adjudicating orders relied on non matching input quantities/values and absence of detailed stock and invoice records. The subsequent production of documents and CA certified stock, invoices and sales registers led to a procedural fairness requirement: the impugned rejections are set aside and the matters remitted for fresh adjudication so the Authority can verify the newly produced evidence and determine validity of TRAN credits. All substantive contentions were left open for reconsideration on the fresh record.

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Issues: Whether the Order in Originals rejecting TRAN 1 and TRAN 2 for the period July 2017 to March 2022 should be set aside and the matters remitted to the Adjudicating Authority for fresh consideration in view of documents and records subsequently produced by the petitioner.

Analysis: The adjudicating orders recorded non matching of quantity and value of inputs with TRAN credit availed and noted absence of detailed stock registers and supporting invoices. Subsequent to the impugned orders, the petitioner produced documents before the Authority (including materials referred to at Annexure E) and the Authority sought CA certified closing stock, purchase invoices and sales register for part of the relevant period. The petitioners were afforded an opportunity to satisfy the Authority by producing supporting records and the Authority has invited further certified copies to verify the claims. In these circumstances, the procedural fairness requirement and the need to consider additional material produced after the original orders warrant setting aside the impugned orders and remitting the matters for fresh adjudication so that the Authority may examine the newly produced evidence and decide on the validity of the TRAN credits.

Conclusion: The impugned Order in Originals rejecting TRAN 1 and TRAN 2 are set aside and both matters are remitted to the Adjudicating Authority for fresh consideration in accordance with law; all contentions are left open.

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