Limited verification, not remand, under the Amnesty Scheme dispute led to rejection of the Revenue's challenge.

The appellate authority's finding that the Amnesty Scheme formula was inapplicable after its expiry was not challenged by the Revenue, and that substantive issue therefore stood. The direction to the Assistant Commissioner was limited to verifying the actual quantum of credit reversed and was not a remand on the merits. Because the Commissioner (Appeals) had already decided the main issue and only sought factual verification of the amount, the Revenue's objection failed. The order of the Commissioner (Appeals) was upheld and the Revenue's appeal was rejected.

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Issues: Whether the Commissioner (Appeals) had remanded the matter or had only directed verification of the actual quantum of credit reversed, and whether the Revenue's appeal against that direction had merit.

Analysis: The Tribunal noted that the Revenue had not challenged the finding on the main legal issue regarding the inapplicability of the Amnesty Scheme formula after its expiry. On the impugned order, the direction to the Assistant Commissioner was confined to verifying the actual amount of credit reversed. Since the appellate authority had itself decided the substantive issue and only called for verification of quantum, the order was not treated as a remand on the merits. The Revenue's objection to that limited verification direction was also found insufficient to warrant interference.

Conclusion: The order of the Commissioner (Appeals) was upheld and the Revenue's appeal was rejected.

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