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2022 (1) TMI 451 - HC - Service TaxSeeking direction to Respondents to accept the application Form SVLDRS-1 filed by the Petitioner and to issue discharge certificate - Petitioner also seeks an opportunity to put forth his case/submissions and for a direction that, a reasoned Order be passed thereafter - requirement of opportunity of personal hearing - principles of natural justice - HELD THAT:- The question, as to, whether the tax liabilities are already quantified or not as on 30th June 2019 itself is a matter of dispute raised by the Petitioner in Writ Petition and also in the application/declaration filed under the said Scheme by the Petitioner before the Authorities. If according to the Respondents the tax liabilities were not quantified and the Petitioner was not eligible, the Respondents ought to have given an opportunity of being heard to the Petitioner before passing such Order rejecting the application made by the Petitioner on the ground of ineligibility. If the Petitioner would have been given an opportunity, the Petitioner would have pointed out the quantification of tax liability during the course of the hearing. In our view, personal hearing was necessary in this situation.
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