S.33A of Central Excise Mandates Three Personal Hearings with Adequate Gaps: Patna HC Remands Matter

The Patna High Court remanded an excise case, holding that Section 33A mandates three substantive personal hearings with reasonable intervals before adjudication. The court found the petitioner was given only two hearings - one virtual and one in-person - violating procedural safeguards. This technical compliance is crucial as it affects the assessee's right to proper defense. The ₹7.8 crore duty demand was set aside, with directions for fresh proceedings adhering strictly to hearing requirements. The judgment reinforces that tax authorities must follow due process scrupulously in high-stakes adjudications. While causing temporary reprieve for the assessee, such remands ultimately prolong litigation when authorities cut procedural corners.