3.It is the case of the petitioner that the respondent had issued a notice stating that the petitioner has reported exempted turnover of Rs.38,62,625/- for the assessment year 2010-11 and requested him to produce the documents in proof of the claim of exemption. The petitioner filed the reply dated 12.12.2017 by enclosing the certificates issued by SEZ dealers in proof of exemption claimed for the turnover of Rs.31,97,465/-. The petitioner also filed details of labour charges for Rs.6,54,520/- in proof of exemption claimed. The respondent verified the certificates issued by SEZ dealers and the details for labour charges and granted exemption on the above turnover of Rs.31,97,465/- and Rs.6,54,520/- respectively. The respondent has stated that the sales have been effected to dealers in Special Economic Zones, but the corresponding ITC has not been made. The respondent has not made any proposal to reverse the ITC on the sales made to SEZ dealers in the notice dated 25.10.2017. The respondent has also not pointed out the order passed by this Court in W.P.No.21453 of 2008 dated 09.01.2015 and has not granted an opportunity to the petitioner to give reply for the said proposal. However, in the impugned order, the respondent has reversed the ITC of Rs.2,00,831/without giving an opportunity to the petitioner to show cause against such order. According to the petitioner, it is violative of principles of natural justice.
