Archana Wadhwa,
1. After hearing both sides, we find that the present appeal stands filed by the appellants against a non-speaking or passed by the Commissioner, which stands followed by the Assistant commissioner while assessing the Bill of Entry. The Bill of Entry stands assessed and classification changed by the Assistant Commissioner by observing as under:-
Bill of Entry assessed as per order of Commissioner vide file No. S/Misc-159/2011 Group 2 ACC.
It is seen that neither the order of the Assistant Commissioner passed on the Bill of Entry is appealable before the Tribunal in as much as the appeal against the same lies before the Commissioner (Appeals), nor the note sheet order of the Commissioner withstands followed by the Assistant Commissioner is in appealable form. In any case, we note that the Assistant Commissioner has simply followed the note sheet instructions of the Commissioner without grant of any opportunity to the appellants to contest the same. As such we deem it appropriate that the proper officer passes a fresh assessment order after extending an opportunity to the appellant to contest the same. We order accordingly.
(Order dictated and pronounced in the open Court)