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Deficiency Memos Not Equivalent to Show Cause Notices: Natural Justice Principles Upheld in CENVAT Credit Refund Case.

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....Violation of the principles of natural justice - Refund of unutilized CENVAT credit - Issuance of Deficiency memo to be treated as Show Cause Notice (SCN) or not - the deficiency memos did not embody a preliminary view or opinion that may have been formed by the second respondent for rejecting the applications for refund - the deficiency memos did not fulfil the rudimentary requirements of an action being imbued and informed by the principles of natural justice. - HC....