Revenue appeal allowed on the same issue, with adjustment of amounts already paid retained subject to record verification.

Following its earlier ruling on the same issue, the Tribunal accepted the Revenue's challenge and allowed the appeal. The lower appellate authority's order was upheld in substance, but the limited direction permitting adjustment of any amount already paid by the respondent against the demand was retained, subject to verification of the records. The result was that the Revenue succeeded, while the adjustment safeguard remained available only on proof from the record.

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Issues: Whether the Revenue's appeal deserved to be allowed and the order of the lower appellate authority sustained only with the limited direction to adjust any amount already paid by the respondent against the demand, subject to verification of records.

Analysis: The Tribunal followed its earlier decision on the same issue and accepted the Revenue's challenge to the order of the lower appellate authority. The direction regarding adjustment of any amount already paid was retained, but only subject to verification of the record.

Conclusion: The appeal was allowed in favour of the Revenue and the lower appellate authority's order was confirmed except for the limited direction permitting adjustment of any amount already paid, subject to verification of records.

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