2014 (1) TMI 167

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....DER The appellants have imported crude petroleum oil and the quantity transferred to their various refineries was more than the quantity imported and consequently at the time of finalisation of the assessment, the duty paid by them was found higher than what was liable to be paid and after finalisation the appellant filed two refund claims which are the subject matter of these two appeals in this....

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....countant submits that the observations of the learned Commissioner that netting out is not in accordance with the accounting principle and has resulted in increase of revenue is totally incorrect. He submits that even if netting is not done ultimate result would be same since in the balance sheet also both the assets and liability increase correspondingly and ultimately even in the balance sheet, ....