Separate Units, Separate Claims: Commissioner's Decision on Gandhar Unit Doesn't Apply to Other Units u/s 11B(1).

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....Time-Barred Refund Claim as per Section 11B(1) - Argument of the appellant that a favourable decision taken by the Commissioner with reference to their Gandhar unit should be taken as a deemed protest for the appellants unit is not acceptable as each registered unit is a separate legal entity - AT....