Show-cause notices invalidated for failing mandatory CBEC pre-consultation; Revenue allowed to initiate consultation within four weeks

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....The HC quashed and set aside the impugned show-cause notices issued to the petitioners for violation of the mandatory pre-consultation procedure prescribed by the CBEC master circulars, finding the circulars binding on the Revenue and the absence of any invoked exception. The court held the pre-consultative requirement material to administrative fairness and trade facilitation; on that ground the SCNs issued without such consultation were invalid. The Revenue was granted liberty to initiate the prescribed pre-consultation by issuing a pre-consultation notice within four weeks from the date of upload of the order. Petition dismissed as disposed of accordingly.....