JUDGMENT : A. Pasayat, J. - All these three applications involve identical dispute and this judgment shall govern each one of them. Petitioner in each case was registered as a dealer under the Orissa Sales Tax Act, 1947 (in short, "the Act"). Sales Tax Officer, Rourkela II circle, panposh (opposite party No. 2 in each case) directed cancellation of the registration certificate granted in purported exercise of power conferred u/s 9(6)(c) of the Act read with Rule 16-A of the Orissa Sales Tax Rules, 1947 (in short, "the Rules"). The order of cancellation was challenged before the Commissioner of Sales Tax, Orissa. By order dated March 11, 1997 the Additional Commissioner of Sales Tax who heard the revision petition in each case, upheld the order directing cancellation of the certificate of registration. Grounds which weighed with the Sales Tax Officer to direct cancellation was the petitioner which was granted the certificate of registration as an S.S.I unit for manufacturing certain articles, was found not to be carrying on any activity whatsoever. No manufacturing activity by the so-called unit was even carried out and no machinery or raw material was noticed in the premises of the petitioners. Sales Tax Officer referred to observations during certain inspections made to conclude that no manufacturing activity was carried on. Notice was issued by the concerned Sales Tax Officer requiring the petitioner in each case to show cause as to why the certificate shall not be cancelled. Reliance was placed by the petitioner on the certificate issued by the General Manager, D.I.C. Sundargarh to further its claim of being a genuine unit engaged in manufacturing activity. Sales Tax Officer came to the conclusion that the certificate of registration had been taken with ulterior motives and articles purchased at concessional rates were being disposed of in unauthorised manner. The stand that absence of regular activities was on account of non-availability of raw materials from the Rourkala Steel Plant, and the machineries had been shifted to a room as the manufacturing activities were suspended for non-availability of raw materials was found to be without substance. 2. The stand that absence of regular activities was on account of non-availability of raw materials from the Rourkala Steel Plant, and the machineries had been shifted to a room as the manufacturing activities were suspended for non-availability of raw materials was found to be without substance. 2. The conclusions of the Sales Tax Officer were challenged before the revisional authority (the Additional Commissioner) who not only took note of the conclusions arrived at by the Sales Tax Officer, but also referred to certain reports submitted by two Sales Tax Officers, who were deputed by him to verify correctness of the petitioner's claim that even after cancellation of registration certificate, manufacturing activities were carried on. The reports submitted by the Sales Tax Officer reflected total lack of activity. Placing reliance on the reports also the revisional authority held that the cancellation was proper. 3. In support of the application Mr. L. Pangari, learned counsel submitted that Section 9(6)(c) of the Act which permits cancellation of certificate of registration is not applicable to the facts of the case. It was also submitted that before utilising the reports of the two Sales Tax Officers no opportunity was granted to the petitioner in each case to have its say in the matter. The learned counsel for revenue, however, supported the order stating that requisite opportunities were granted and in the circumstances action u/s 9(6)(c) was proper. 4. Section 9(6)(c) authorises cancellation of registration with effect from the prescribed date, if any sufficient reason, which is not covered by contingencies enumerated under Clauses (a) and (b) exists. Section 9(6)(c) reads as follows : "(c) there is any other sufficient reasons so to do, the Commissioner shall cancel the registration with effect from the prescribed date and on such cancellation the Commissioner may, on application in the prescribed form received within six months of the date of cancellation, refund in such manner and subject to such conditions as may be prescribed, the security, if any, paid under Sub-section (3-a)." Where it is noticed by an officer that there has been misutilisation of the certificate of registration and/or the certificate has been obtained by suppressing material facts or it has been obtained with ulterior motives, the certificate of registration can be cancelled. Where there has been discontinuance once or entire transfer of business, Section 9(6)(c) can be applied. Where there has been discontinuance once or entire transfer of business, Section 9(6)(c) can be applied. In the case at hand, action was taken u/s 9(6}(c) on the ground that during inspection of the unit no, manufacturing activities were being carried on and machineries and raw materials required for the purpose were also not found there. Rule 16A(1) of the rules provides that if the Sales Tax Officer for any good and sufficient reason, finds that the registration of any dealer is required to be cancelled under Clause (c) of Sub-section (6) of Section 9 he may, after giving the dealer a reasonable opportunity of being heard, wherever practicable, may order cancellation of the registration with effect from a date to be specified in the order. Reasons are the links between the materials on which certain conclusions are based and the actual conclusions. The word "sufficient" means "adequate", "enough", "as much as may be necessary to answer the purpose intended". It embraces no more that which provides a plentitude which, when done, suffices to accomplish the purpose intended in the light of existing circumstance, and when viewed from reasonable standard of practical and cautious men. The expression "sufficient reason" implies presence of legal and adequate reason. Obviously the Sales Tax Officer has power to direct cancellation where really no manufacturing activity in carried on, and/or the registration is obtained with oblique motive to evade tax resulting in loss to State exchequer. Whether there is any lack or total absence of activity has to be adjudicated on facts, when the petitioner asserts that it is carrying on the activities, and the sales tax authorities think otherwise. As the matter was before the revisional authority, it was required to give definite finding on that aspect. 5. We find from records produced before us by the learned counsel for revenue that on March 11, 1997, the Additional Commissioner directed two officers to submit their separate reports on the question whether any manufacturing was being carried on at the concerned units. The reports were received later that day. There is no material on record that those reports were brought to the notice of the petitioner in each case. The reports have been utilised for drawing adverse inference against each of the petitioners. Therefore, the petitioners were entitled to be made aware of the materials which were sought to be utilised against them. There is no material on record that those reports were brought to the notice of the petitioner in each case. The reports have been utilised for drawing adverse inference against each of the petitioners. Therefore, the petitioners were entitled to be made aware of the materials which were sought to be utilised against them. That has not been done. Principles of natural justice in the process have been violated. One of the accepted, and universally recognised maxims relating to essential characteristic of natural justice is, as put by Romans, "audi alteram partem" (hear both sides). The aim of rules of nature justice is to secure justice to prevent miscarriage of justice. The person affected must have (i) a reasonable opportunity of being heard, (ii) the hearing must be a genuine hearing and not an empty formality. Materials to be relied upon against a person should be disclosed to him. 6. Above being the position, order of the Additional Commissioner (annexure 14 in each case), is vitiated, and is set aside. We remit the matter back to him for fresh disposal. We make it clear that we have not expressed any opinion on merits. Direction for reconsideration is in view of violation of principles of natural justice. The Additional Commissioner shall bring to notice of the petitioner in, each case the materials proposed to be utilised against it. The reports need not be furnished in entirety to the concerned petitioner, and only the relevant materials which were intended to be utilised shall be brought to its notice. To avoid unnecessary delay petitioner in each case is directed to appear before the revisional authority on 5th August, 1997 when further date shall be fixed by the revisional authority for de novo hearing. The writ application are allowed to the extent indicated above. No cost. S.C. Datta, J. 7. I agree. Final Result : Allowed