Customs Valuation Rule Sequence must be followed; single-comparator re-determination and penalties set aside without comparability or proof of mis-dec...
Separately Identifiable Services: transportation found to be the essential character, so Cargo Handling classification and extended limitation rejecte...
Principles of issue estoppel and administrative finality constrain a subordinate appellate authority from revisiting or nullifying its earlier appellate findings when granting consequential relief; the commentary applies res judicata and Evidence Act principles by analogy to quasi judicial tax proceedings and rejects re litigation where the appellate order was accepted by the department. The noted decision found the Commissioner (Appeals) improperly refused relief already adjudicated in an earlier Appellate Order, set aside that refusal, and remitted the matters for fresh consideration on merits while prohibiting re opening settled appellate conclusions.
Principles of issue estoppel and administrative finality constrain a subordinate appellate authority from revisiting or nullifying its earlier appellate findings when granting consequential relief; the commentary applies res judicata and Evidence Act principles by analogy to quasi judicial tax proceedings and rejects re litigation where the appellate order was accepted by the department. The noted decision found the Commissioner (Appeals) improperly refused relief already adjudicated in an earlier Appellate Order, set aside that refusal, and remitted the matters for fresh consideration on merits while prohibiting re opening settled appellate conclusions.
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