Accepting this position, the High Court remitted the matter to the concerned authority. The Court set aside the impugned order dated 24.07.2025 and permitted the respondents to pass a fresh order in accordance with law after affording the petitioner a personal hearing. The Court further directed that all legal and factual issues would remain open for consideration before the concerned authority. In view of the fair stand taken by learned counsel for the respondents-revenue, this matter is remitted back to the authority concerned. It is further provided that all legal and factual issues shall remain open for consideration before the authority concerned.