TMI Blog2022 (4) TMI 1572X X X X Extracts X X X X X X X X Extracts X X X X ..... nt - apparent error in the order or not - Appellant submits that the remand may be made open for the issue of limitation as well as penalty for re-considering not only on Revenue neutrality but otherwise also - HELD THAT:- It is found that in Para 4.3, though the matter was remanded on the issue of limitation as well as imposition of penalty but it is confined to the point of Revenue neutrality. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r reconsideration of limitation as well as imposition of penalty on Revenue neutrality. 2. Ms. Dimple Gohil, learned Counsel submits that the remand may be made open for the issue of limitation as well as penalty for re-considering not only on Revenue neutrality but otherwise also. 3. Shri J. A Patel, learned Superintendent (AR) supports the order of this Tribunal. He submits that since the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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