Binding remand directions require reasoned reconsideration; summary rejection of customs exemption was set aside and relief upheld.

A remand order binds the authority reconsidering the matter, and any fresh decision must address the specific issues remanded with reasoned findings. Here, the first appellate authority rejected the customs exemption without dealing with the original authority's basis for granting relief or with the remand directions, making the summary rejection unsustainable. The original exemption was therefore upheld and the contrary appellate order was set aside, leaving the assessee entitled to retain the customs exemption granted at the initial stage.

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Issues: Whether the first appellate authority complied with the Tribunal's remand order and whether the exemption granted by the original authority under the relevant customs notifications was liable to be set aside.

Analysis: The remand order of the Tribunal was binding on the authorities dealing with the matter after remand. The first appellate authority rejected the benefit of exemption without addressing the basis on which the original authority had extended the benefit and without proper discussion of the issues remanded for reconsideration. Such a summary rejection was held to be unsustainable and contrary to the remand directions.

Conclusion: The exemption granted by the original authority was upheld and the contrary appellate order was set aside.

Final Conclusion: The appeal succeeded and the assessee retained the customs exemption granted by the original adjudicating authority.

Ratio Decidendi: A remand order is binding on the authorities before whom the matter is reconsidered, and an appellate authority cannot discard the original relief without addressing the remanded issues through reasoned findings.

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