Revenue Must Initiate Proceedings to Confirm Amount; Refund Allowed Due to Lack of Show-Cause Notice Against Appellants.

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....Denial of refund claim - Once the debit is made at the instructions of the audit team, the Revenue is under a legal obligation to initiate proceedings for confirmation of the amount in question, by deciding on the disputed legal issue. No such proceedings, by way of show-cause notice stands initiated against the appellants - refund allowed - AT....