Departmental appeal limitation after recall from the call book...

Departmental appeal limitation after recall from the call book is determined by the original filing date; administrative renumbering does not create a fresh appeal or make it time-barred. For special additional duty refund on imported plastic granules, generic sale-invoice descriptions did not negate correlation where Bills of Entry, sale invoices, reconciliation, VAT/CST payment records and a Chartered Accountant's certificate supported the claim. Sales through consignment agents did not independently justify rejection absent a specific documentary defect. Wikipedia material could not displace contemporaneous import and sale records. The refund sanction was restored, while the departmental appeal failed on merits.