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    <title>2020 (4) TMI 805 - CESTAT NEW DELHI</title>
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    <description>Refund of Special Additional Duty was treated as unavailable only for substantive non-fulfilment, not for mere omission of the invoice declaration where the underlying purpose of preventing inadmissible buyer credit was otherwise satisfied. The text also states that a refund could not be denied on unjust enrichment or any other ground not proposed in the show cause notice, and that a Chartered Accountant&#039;s certificate was accepted in the absence of a contrary notice-based case. The stated principle is that an appellate authority cannot sustain rejection on a new ground introduced beyond the show cause notice, and procedural defects alone do not defeat substantive refund entitlement.</description>
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