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The court examined whether the impugned order violated principles of natural justice by not considering contentions raised by the petitioner and being non-speaking regarding certain claim heads. The court held that quasi-judicial authorities must record reasons, though not as elaborate as court judgments. Upon examination, the court found that while reasons were specified for classification under CTH 8301, vital contentions regarding GRI and Explanatory Notes were not considered. To balance revenue interests, the court set aside the order on condition that the petitioner remits Rs. 1.75 crore, exceeding 5% of the disputed tax demand under this head, within four weeks. The assessing officer was directed to provide a reasonable opportunity, including a personal hearing, and issue a fresh order within three months after receiving the petitioner's reply.
The court examined whether the impugned order violated principles of natural justice by not considering contentions raised by the petitioner and being non-speaking regarding certain claim heads. The court held that quasi-judicial authorities must record reasons, though not as elaborate as court judgments. Upon examination, the court found that while reasons were specified for classification under CTH 8301, vital contentions regarding GRI and Explanatory Notes were not considered. To balance revenue interests, the court set aside the order on condition that the petitioner remits Rs. 1.75 crore, exceeding 5% of the disputed tax demand under this head, within four weeks. The assessing officer was directed to provide a reasonable opportunity, including a personal hearing, and issue a fresh order within three months after receiving the petitioner's reply.
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