Limited remand in refund dispute confined to FIRC correlation issue, with unchallenged findings left undisturbed.

Refund claims were remanded for fresh examination after the appellate authority rejected them only on the alleged mismatch between FIRC and export service invoices. Because the other objections recorded in the original order were not dealt with in appeal and were not challenged by the Revenue, those issues could not be reopened on remand. The adjudicating authority was directed to reconsider the matter only on the limited FIRC correlation issue, leaving the unappealed findings undisturbed.

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Issues: Whether the refund claims rejected on the ground of alleged mismatch between FIRC and export service invoices required fresh consideration, and whether the remand could be confined only to that issue.

Analysis: The refund claims related to two periods and the Commissioner (Appeals) had rejected them only on the FIRC correlation issue, though the original order had recorded several objections. Since the appellate authority had not dealt with the other issues and the Revenue had not appealed against those findings, those aspects could not be reopened. The matter therefore required reconsideration only on the limited question relating to FIRC, with reference to the earlier interim order cited in the decision.

Conclusion: The impugned orders were set aside and the matter was remanded to the original adjudicating authority for fresh examination confined to the FIRC issue.

Final Conclusion: The assessee obtained a partial relief by securing a limited remand, while the dispute on refund remained open for fresh adjudication only on the specified issue.

Ratio Decidendi: Where an appellate authority has decided a refund dispute only on one specified ground and other findings are not challenged, remand proceedings must remain confined to the issue actually decided and cannot reopen unappealed matters.

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