Consequential relief under a revisional order cannot be curtailed by reapplying limitation to settled refund claims.

An unconditional revisional order granting consequential relief could not be reopened by subordinate authorities to re-examine refund claims or curtail them by applying Rule 11. The revisional authority had already dealt with the matter, and the lower authorities were bound only to implement that order. They therefore lacked jurisdiction to invoke limitation afresh against claims already covered by the revision. The remaining refund amounts had to be paid in accordance with the revisional order.

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Issues: Whether the lower authorities could restrict the refund claims by applying limitation under Rule 11 after an unconditional revisional order had directed consequential relief.

Analysis: The revisional order was unconditional and did not indicate that any aspect of the claim had been left open for fresh scrutiny. In these circumstances, the lower authorities were not competent to interpret the expression "consequential relief" so as to reopen the merits of the refund claims or to cut them down by invoking Rule 11. The matter had already been considered at the revisional stage, and the subordinate authorities could only implement that order.

Conclusion: The lower authorities lacked jurisdiction to re-examine the refund claims with reference to Rule 11, and the remaining refund amounts were directed to be paid.

Final Conclusion: The assessee succeeded on the core dispute, and the disputed refund claims had to be given effect in accordance with the revisional order.

Ratio Decidendi: A subordinate authority cannot reopen or curtail relief granted by an unconditional revisional order by independently reapplying a limitation rule to matters already covered by that order.

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