https://www.taxtmi.com/caselaws?id=51436 The dominant issue was whether the refund claim was barred by limitation in light of enhancement of assessable value at assessment. The Tribunal held that where assessable value was enhanced on the bill of entry without a separate speaking order and the importer challenged that enhancement in appeal, the appeal itself constitutes protest; consequently, the refund claim could not be rejected on limitation without first adjudicating the correctness of valuation. The Commissioner (Appeals) was therefore required to decide the valuation dispute on merits after granting reasonable opportunity of hearing. The impugned order was set aside and the matter was remanded to the Commissioner (Appeals) for fresh decision on valuation, with the appeal allowed by way of remand. en-us Wed, 03 Jul 2002 00:00:00 +0530 Wed, 07 Jan 2026 15:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=51436 The dominant issue was whether the refund claim was barred by limitation in light of enhancement of assessable value at assessment. The Tribunal held that where assessable value was enhanced on the bill of entry without a separate speaking order and the importer challenged that enhancement in appeal, the appeal itself constitutes protest; consequently, the refund claim could not be rejected on limitation without first adjudicating the correctness of valuation. The Commissioner (Appeals) was therefore required to decide the valuation dispute on merits after granting reasonable opportunity of hearing. The impugned order was set aside and the matter was remanded to the Commissioner (Appeals) for fresh decision on valuation, with the appeal allowed by way of remand. Case-Laws Customs Wed, 03 Jul 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=51436