https://www.taxtmi.com/caselaws?id=795408 Refund classification depends on whether the assessee demonstrably raised a claim under Section 27 before the Commissioner (Appeals). Although the adjudicating authority treated the refund under Section 26A after the assessee altered its position, the asserted subsequent Section 27 plea could not be examined without the appeal memorandum, grounds, or written submissions. The matter is remitted for verification of the prior pleadings. If a Section 27 claim is established, the refund must be decided on merits under that provision; otherwise, it remains confined to Section 26A. en-us Mon, 20 Jul 2026 00:00:00 +0530 Wed, 22 Jul 2026 09:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795408 Refund classification depends on whether the assessee demonstrably raised a claim under Section 27 before the Commissioner (Appeals). Although the adjudicating authority treated the refund under Section 26A after the assessee altered its position, the asserted subsequent Section 27 plea could not be examined without the appeal memorandum, grounds, or written submissions. The matter is remitted for verification of the prior pleadings. If a Section 27 claim is established, the refund must be decided on merits under that provision; otherwise, it remains confined to Section 26A. Case-Laws Customs Mon, 20 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795408