Held - The respondents have also stated in their written instructions that once a detailed reply is sent by the petitioner stating their objections with regard to the impugned show cause notice, the same will be considered by them on merits. They have also categorically stated in their written instructions that if the defects are similar to the one mentioned in the show cause notice issued by the Central Authority, the said defects will be omi.....

Held - The learned standing counsel appearing for the respondents, on instructions, submitted that the three wings of the department are proceeding against the appellants because the Range office was not aware about the proceedings initiated by the Audit Commissionerate and the Anti Evasion also was not aware of the same. It is not clear as to why in the present days of electronic communications available in the department, such parallel proce.....

Held - We find that such a procedure had not been adopted in the instant case and the appellants appears to have been dealt with in a most unfair manner in the sense that from the year 2018 for the very same TRAN – 1 issue the appellants have repeatedly been summoned, issued notices etc. The spot memos, which have been communicated to the appellants along with the communications dated 22nd March, 2021 is also for the very same purpose.