Facts: The assessee challenged an adjudication order citing denial of natural justice-no hearing, no chance to file written reply, and refusal to allow cross-examination. The writ was filed late, in January 2025, against a July 2024 order. The Single Judge still allowed the assessee to file an appeal under section 107. The assessee also claimed a refund was earlier granted, proving genuineness, and requested adjustment of recovered amounts as pre-deposit.
Judgment: The Court held that the case required detailed factual adjudication and was not fit for bypassing the statutory appeal. It upheld the Single Judges view and dismissed the intra-court appeal. The assessee was directed to file a statutory appeal within 30 days. All issues can be raised before the appellate authority, which must also consider the request for adjusting recovered amounts towards pre-deposit.

Facts: The assessee challenged an adjudication order citing denial of natural justice-no hearing, no chance to file written reply, and refusal to allow cross-examination. The writ was filed late, in January 2025, against a July 2024 order. The Single Judge still allowed the assessee to file an appeal under section 107. The assessee also claimed a refund was earlier granted, proving genuineness, and requested adjustment of recovered amounts as pre-deposit.
Judgment: The Court held that the case required detailed factual adjudication and was not fit for bypassing the statutory appeal. It upheld the Single Judges view and dismissed the intra-court appeal. The assessee was directed to file a statutory appeal within 30 days. All issues can be raised before the appellate authority, which must also consider the request for adjusting recovered amounts towards pre-deposit.

Facts: The assessee challenged an adjudication order citing denial of natural justice-no hearing, no chance to file written reply, and refusal to allow cross-examination. The writ was filed late, in January 2025, against a July 2024 order. The Single Judge still allowed the assessee to file an appeal under section 107. The assessee also claimed a refund was earlier granted, proving genuineness, and requested adjustment of recovered amounts as pre-deposit.
Judgment: The Court held that the case required detailed factual adjudication and was not fit for bypassing the statutory appeal. It upheld the Single Judges view and dismissed the intra-court appeal. The assessee was directed to file a statutory appeal within 30 days. All issues can be raised before the appellate authority, which must also consider the request for adjusting recovered amounts towards pre-deposit.

Facts: The assessee challenged an adjudication order citing denial of natural justice-no hearing, no chance to file written reply, and refusal to allow cross-examination. The writ was filed late, in January 2025, against a July 2024 order. The Single Judge still allowed the assessee to file an appeal under section 107. The assessee also claimed a refund was earlier granted, proving genuineness, and requested adjustment of recovered amounts as pre-deposit.
Judgment: The Court held that the case required detailed factual adjudication and was not fit for bypassing the statutory appeal. It upheld the Single Judges view and dismissed the intra-court appeal. The assessee was directed to file a statutory appeal within 30 days. All issues can be raised before the appellate authority, which must also consider the request for adjusting recovered amounts towards pre-deposit.

Facts: The assessee challenged an adjudication order citing denial of natural justice-no hearing, no chance to file written reply, and refusal to allow cross-examination. The writ was filed late, in January 2025, against a July 2024 order. The Single Judge still allowed the assessee to file an appeal under section 107. The assessee also claimed a refund was earlier granted, proving genuineness, and requested adjustment of recovered amounts as pre-deposit.
Judgment: The Court held that the case required detailed factual adjudication and was not fit for bypassing the statutory appeal. It upheld the Single Judges view and dismissed the intra-court appeal. The assessee was directed to file a statutory appeal within 30 days. All issues can be raised before the appellate authority, which must also consider the request for adjusting recovered amounts towards pre-deposit.

Facts: The assessee challenged an adjudication order citing denial of natural justice-no hearing, no chance to file written reply, and refusal to allow cross-examination. The writ was filed late, in January 2025, against a July 2024 order. The Single Judge still allowed the assessee to file an appeal under section 107. The assessee also claimed a refund was earlier granted, proving genuineness, and requested adjustment of recovered amounts as pre-deposit.
Judgment: The Court held that the case required detailed factual adjudication and was not fit for bypassing the statutory appeal. It upheld the Single Judges view and dismissed the intra-court appeal. The assessee was directed to file a statutory appeal within 30 days. All issues can be raised before the appellate authority, which must also consider the request for adjusting recovered amounts towards pre-deposit.