Final valuation remand complied with; no further duty re-working was required and the demand was sustained.

An earlier appellate decision had already settled the central excise valuation dispute, leaving only a limited remand to verify whether the cost of the pancake master tape had been amortised over the cassettes manufactured. The Tribunal found that the de novo authority had already taken that factor into account and that no further re-working of duty was required. As the limited remand direction stood complied with and the assessee had not reopened the merits determination, no fresh grievance survived. The confirmation of duty, penalty and interest was therefore sustained and the appeal was dismissed.

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Issues: (i) Whether the earlier appellate determination on central excise valuation had attained finality and whether any further re-working of duty was required only on account of amortisation of the cost of the pancake master tape.

Analysis: The earlier order had already decided the valuation dispute against the assessee and remanded the matter only for the limited purpose of verifying whether the cost of the pancake master tape had been amortised over the number of cassettes manufactured. On examination of the de novo order, the Tribunal found that the adjudicating authority had already taken that factor into account and had recorded that the duty computation required no further interference. Since the only surviving direction had been complied with and the assessee had not successfully challenged the earlier merits determination, no fresh grievance remained open.

Conclusion: The issue was decided against the assessee, and the duty, penalty, and interest confirmation was sustained.

Final Conclusion: The impugned order was held to be valid in law and the appeal was dismissed, leaving the Revenue's valuation and demand intact.

Ratio Decidendi: Where an earlier appellate decision has conclusively settled the substantive valuation dispute and remand is confined to a limited computational verification, compliance with that limited direction precludes further challenge to the confirmed demand.

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