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    <title>2020 (9) TMI 79 - MADRAS HIGH COURT</title>
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    <description>Merits-based contentions not raised before the Tribunal were declined in appeal because they had not been urged below and were not addressed in the impugned order. The Court also noted that the Tribunal had proceeded on the basis that Rule 96ZQ had been struck down, and therefore the adjudication order could not be sustained on that footing. The appeal was not entertained on merits, and the Revenue was left at liberty to seek review or file a miscellaneous petition before the Tribunal so that all contentions could be considered in the first instance.</description>
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      <title>2020 (9) TMI 79 - MADRAS HIGH COURT</title>
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      <description>Merits-based contentions not raised before the Tribunal were declined in appeal because they had not been urged below and were not addressed in the impugned order. The Court also noted that the Tribunal had proceeded on the basis that Rule 96ZQ had been struck down, and therefore the adjudication order could not be sustained on that footing. The appeal was not entertained on merits, and the Revenue was left at liberty to seek review or file a miscellaneous petition before the Tribunal so that all contentions could be considered in the first instance.</description>
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