Mere change of opinion cannot justify setting aside provisional...

Mere change of opinion cannot justify setting aside provisional assessments. Eligibility for abatement on value of bought-out items cannot be denied without findings on availment of CENVAT credit. Non-verification of actual purchase price of directly supplied bought-out items is not a valid ground for setting aside assessments. Appellate Authority erred by setting aside assessments based on change of opinion without finding violation of guidelines or revenue loss. Assessments finalized following Office Memorandum guidelines are binding unless resulting in revenue loss. Impugned order set aside, appeal allowed.

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