Fresh adjudication on merits allowed after partial tax deposit, reply filing, and lifting of bank attachment on compliance.

The writ petition was disposed of by remitting the adjudication for fresh decision on merits, after the petitioner consented to deposit 25% of the disputed tax and file a reply with supporting documents. The Court noted that the adjudication order had been passed without response to the show cause notice or participation in personal hearings, and treated the impugned order as an addendum to the notice for reconsideration. It also recorded that the statutory appeal period had expired, but relief was granted on the stated conditions. Any bank attachment was directed to stand lifted upon compliance with those conditions.

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Issues: Whether the writ petition should be disposed of by remitting the matter for fresh adjudication on merits, subject to payment of a portion of the disputed tax and filing of a reply.

Analysis: The challenge arose from an adjudication order passed after the petitioner did not respond to the show cause notice or attend the personal hearings. The Court noted that the statutory appeal period had already expired, but recorded the petitioner's consent to deposit 25% of the disputed tax and to file a reply with supporting documents. On that basis, the matter was sent back for fresh consideration on merits, with a direction to treat the impugned order as an addendum to the show cause notice. The Court also directed that any bank attachment would stand lifted upon compliance with the stipulated conditions.

Conclusion: The matter was remitted to the respondent for fresh adjudication on merits, subject to the petitioner depositing 25% of the disputed tax and filing a reply within the prescribed time.

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