Remand confined to reassessment cannot support a fresh finding of notification eligibility; documentary compliance must be re-examined.

Where the appellate prayer was confined to remand for reassessment, the Commissioner (Appeals) should not have gone further and recorded a substantive finding on eligibility to the customs notification. The appellate order was therefore modified to that extent, and the matter was remanded to the original authority to reconsider entitlement to concessional duty after examining the country-of-origin certificates and the applicable customs notifications, including the time-limit for producing such certificates within 12 months from shipment.

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Issues: Whether the Commissioner (Appeals) could grant substantive eligibility to the notification when the respondent had sought only remand for reassessment, and whether the matter should be remanded to the original authority to consider the belated country-of-origin certificates and the time-limit for production of such certificates.

Analysis: The prayer before the Commissioner (Appeals) was confined to remand for reassessment after considering the country-of-origin certificates. The appellate order, however, went beyond that prayer by recording a finding that the respondent was eligible for the benefit of the notification. As the certificates had been produced, the matter required reconsideration by the original authority. The applicable notification also had to be examined along with the companion customs notification governing production of the certificate within 12 months from the date of shipment.

Conclusion: The finding on eligibility was set aside to that extent, and the matter was remanded to the original authority to examine entitlement to concessional duty after considering the country-of-origin certificates and the relevant notifications.

Final Conclusion: The dispute was returned for fresh consideration on entitlement to the customs concession, and the appellate order stood modified accordingly.

Ratio Decidendi: Where the appellate relief sought is limited to remand, a finding granting substantive entitlement beyond that prayer should not be sustained, and the proper course is to remit the matter for reconsideration on the relevant documentary compliance.

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