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The appeal challenged an Order-in-Appeal regarding the loading of invoice value by 20% in finalizing the assessment. The Commissioner (Appeals) stated that such loading without justification cannot be sustained. The finalization of the assessment was set aside, and if finalized in compliance, it would be treated as provisional for the department to finalize after necessary inquiry. The Tribunal found no justification for ordering a re-finalization of the assessment and allowed the appeal with consequential relief.
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