Revenue Cannot Reclaim SAD Refund Without Contesting Prior Order u/s 128; Assessee Also Cannot Seek Refund.

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....Recovery of Refund of SAD - Neither the assessee can seek refund nor Revenue can proceed to recover the refund already sanctioned without challenging the earlier order by way of remedy provided in Section 128 of the Act. Having not challenged the previous order, the Revenue cannot be allowed to re-open the issue - AT....