Single-member Tribunal jurisdiction limited by monetary threshold; refund dispute beyond the limit required rehearing by a larger Bench.

Section 35D of the Central Excise Act, read with section 129C of the Customs Act, limits single-member disposal to cases where the disputed duty or specified amount does not exceed the prescribed monetary threshold. Where a refund of Cenvat credit exceeded that limit, disposal by a Single Member was contrary to the statutory scheme and lacked jurisdiction. The impugned order could not stand and had to be set aside, with the matter to be reheard by a Bench of not less than two Members.

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Issues: Whether a Single Member of the Appellate Tribunal could validly decide an appeal involving refund of Cenvat credit exceeding the monetary limit prescribed for single-member disposal, and whether the impugned order was without jurisdiction.

Analysis: Section 35D of the Central Excise Act, 1944, read with section 129C of the Customs Act, 1962, limits single-member disposal to cases where the disputed duty or other specified amount does not exceed ten lakh rupees. The refund claim in question exceeded that limit. Since the appeal was disposed of by a Single Member despite the statutory restriction, the order suffered from lack of jurisdiction and could not stand.

Conclusion: The impugned order was jurisdiction and was liable to be set aside. The matter was required to be heard afresh by a Bench consisting of not less than two Members.

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