Equalised deduction claims cannot be reopened on remand; authorities may only verify the figures and supporting records.

Once the admissibility of equalised deductions had already been allowed by unchallenged Tribunal and High Court orders, the adjudicating authority could not reopen that settled legal question. Its role on remand was limited to factual verification of the claimed amounts, including examination of books, vouchers and supporting particulars on a test-check basis, with reasons required if the chartered accountant's certificate was rejected. A roving demand for excessive documents was not permitted. The substantive entitlement to the deductions remained undisturbed, and only the accuracy of the figures was left for verification.

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Issues: (i) Whether the deductions claimed on an equalised basis could be denied when the earlier Tribunal and High Court orders allowing such deductions had not been challenged. (ii) What was the permissible scope of verification on remand by the adjudicating authority.

Issue (i): Whether the deductions claimed on an equalised basis could be denied when the earlier Tribunal and High Court orders allowing such deductions had not been challenged.

Analysis: The impugned order was passed in disregard of the earlier binding orders which had already allowed the deductions in principle. In that situation, the lower authority had no jurisdiction to reopen the settled question whether such deductions were admissible. The only surviving exercise was to verify the correctness of the figures and supporting particulars furnished by the assessee.

Conclusion: The denial of equalised deductions was impermissible, and the issue stood in favour of the assessee.

Issue (ii): What was the permissible scope of verification on remand by the adjudicating authority.

Analysis: The matter was remanded only for factual verification of the claimed amounts. The adjudicating authority was directed to examine the books of account and relevant vouchers on test-check basis, or through a suitably qualified person if necessary, and to record reasons if the chartered accountant's certificate was not accepted. A roving demand for excessive documents was discouraged.

Conclusion: The adjudicating authority was confined to verification of figures and could not re-adjudicate the admissibility of the deductions.

Final Conclusion: The appeal succeeded to the extent that the impugned orders were set aside and the matter was sent back only for limited factual verification, with the substantive entitlement to the deductions left undisturbed.

Ratio Decidendi: Once the admissibility of a deduction has been conclusively decided by an unchallenged higher order, the adjudicating authority cannot reopen that legal issue and may only verify the factual correctness of the claim on remand.

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