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    <title>2022 (4) TMI 200 - CESTAT MUMBAI</title>
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    <description>Material contradictions in the lower authorities&#039; findings on production and consideration of credit registers, together with an incorrect view of the period for which records were submitted, justified setting aside the impugned orders. The first appellate authority failed to independently examine these inconsistencies and merely affirmed the original findings. The plea based on the Board circular was raised only before the Tribunal, so it had not been considered below. The matter was therefore remanded for de novo adjudication on all issues, including limitation, after granting the appellant a proper opportunity to place documents and contentions on record.</description>
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      <description>Material contradictions in the lower authorities&#039; findings on production and consideration of credit registers, together with an incorrect view of the period for which records were submitted, justified setting aside the impugned orders. The first appellate authority failed to independently examine these inconsistencies and merely affirmed the original findings. The plea based on the Board circular was raised only before the Tribunal, so it had not been considered below. The matter was therefore remanded for de novo adjudication on all issues, including limitation, after granting the appellant a proper opportunity to place documents and contentions on record.</description>
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