Taxpayer's Refund Claim Rejection Overturned Due to Lack of Show Cause Notice and Order Issuance Opportunity.

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....Refund claim - payment of tax under protest - rejection of refund on the ground of taxability of activity - By not issuing a show cause notice and a consequential order, the assessee was denied the opportunity to challenge the contention of Revenue on taxability - order rejecting the refund claim on ground of taxability is not sustainable - AT....