De novo proceedings must follow remand directions strictly; a belated challenge to the remand cannot undo a compliant fresh order.

In de novo proceedings, the adjudicating authority must comply strictly with the Tribunal's remand directions and cannot travel beyond them. Where the remand required re-determination of assessable value in accordance with CAS-4, compliance with that direction could not be treated as an error. A later challenge to the remand order itself was impermissible and should have been pursued in appropriate appellate proceedings when the remand was made. The Revenue's attempt to upset the fresh order amounted in substance to a belated attack on the earlier remand, and the fresh order passed in conformity with the remand directions was upheld.

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Issues: Whether, in de novo proceedings, the adjudicating authority was bound to follow the Tribunal's remand directions requiring valuation in accordance with CAS-4, and whether the Revenue could seek reversal of the fresh order on the ground that such valuation had been accepted pursuant to those directions.

Analysis: The remand order had specifically directed re-determination of assessable value in accordance with CAS-4. In de novo adjudication, the adjudicating authority was required to act strictly within those directions and could not deviate from them. A challenge to the remand directions themselves ought to have been pursued in appropriate appellate proceedings at that stage. The appeal did not raise any substantive infirmity in the de novo findings and, in substance, amounted to an attempt to review the Tribunal's earlier remand order, which was impermissible.

Conclusion: The Revenue's challenge was rejected and the fresh order passed in compliance with the remand directions was upheld.

Ratio Decidendi: In de novo proceedings, the adjudicating authority is bound by the appellate remand directions and cannot be faulted for following them; a belated attack on the remand itself does not furnish a valid ground to set aside the fresh order.

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