Refund admissibility may be remanded for fresh verification when merits are settled but supporting documents are incomplete.

Where refund entitlement has already been accepted on merits but the record is incomplete, the matter may be restored to the original adjudicating authority for fresh examination of admissibility on the basis of the missing documents. The appellate authority's favourable findings on wrong notification reference and ineligibility of terminal handling charges were left undisturbed and remained binding below. The remand was limited to deciding the refund claim after considering the relevant documents, so the merits findings attained finality while factual verification on admissibility was reopened at the original stage.

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Issues: Whether the refund claims were required to be remanded for fresh adjudication after the Commissioner (Appeals) had accepted the assessee's case on merits but declined relief for want of supporting documents.

Analysis: The refund claims had been rejected at the original stage on grounds of wrong notification reference and ineligibility of terminal handling charges, but the appellate authority took a favourable view on those merits. The rejection at the appellate stage was only because the relevant documents were not before the authority, and the appellate authority was treated as lacking power to remand. In these circumstances, the proper course was to restore the matter to the original adjudicating authority so that admissibility of refund could be examined on the basis of the documents. The appellate authority's findings on eligibility of refund were left undisturbed and were to be followed below.

Conclusion: The matter was remanded to the original adjudicating authority for fresh decision on admissibility of refund after considering the documents, while the favourable findings on merits attained finality.

Ratio Decidendi: Where the appellate authority has reached a final favourable finding on the merits but the record is incomplete for deciding admissibility, remand may be ordered so the original authority can decide the claim on the existing final merits findings and the relevant documents.

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