Allowing the petition the Court held that the Department had sought to withdraw the benefit granted to the assessee under the Act entailing adverse consequences without affording the assessee sufficient opportunity of hearing or making submissions. Considering that form 3 had already been issued on the declarations and undertaking filed by the assessee, any action thereon entailing adverse consequences, ought to have afforded the assessee with a fair and reasonable opportunity to explain its case, which the Revenue had ex facie failed to offer. The order of revocation of form 3 was not valid.( AY. 2011-12)