Limited remand binds the adjudicating authority, so reopening issues beyond the remitted scope could not sustain demand or penalty.

In de novo proceedings following a limited remand, the adjudicating authority was bound to confine itself to the specific factual issue remitted for determination and could not reopen unrelated matters already covered by the Tribunal's earlier final decision. Because the authority went beyond the remand direction and examined issues such as tariff restructuring and classification reasoning instead of only comparing the Pune and Ankleshwar processes, the order was held unsustainable. The demand and penalty were therefore set aside in favour of the assessee.

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Issues: Whether the adjudicating authority, in de novo proceedings after a limited remand, could go beyond the remand direction and reopen issues already covered by the Tribunal's earlier decision, and whether the demand and penalty could therefore be sustained.

Analysis: The matter had earlier been remanded only for the limited purpose of verifying whether the process at the Pune unit was the same as that at the Ankleshwar unit. The earlier Tribunal decision in the Ankleshwar matter had attained finality and was applicable if the factual process was identical. In de novo adjudication, the authority nevertheless examined unrelated aspects, including tariff restructuring and classification reasoning, instead of confining itself to the specific factual comparison directed by the Tribunal. The Tribunal held that once a matter is remanded for a restricted purpose, the lower authority is bound by that direction and cannot travel beyond it to reopen the entire controversy.

Conclusion: The impugned order could not be sustained because the adjudicating authority exceeded the scope of the remand and failed to follow the binding direction. The appeal succeeded and the demand and penalty were set aside in favour of the assessee.

Ratio Decidendi: A lower authority acting on remand is bound strictly by the scope of the remand order and cannot decide matters beyond the limited issue remitted for determination.

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