Commissioner Oversteps by Revisiting Issue Resolved by Tribunal; Violates Doctrine of Merger and Tribunal's Specific Directions.

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....Doctrine of Merger - under the Doctrine of Merger, the Commissioner was not correct in re-visiting the issue which was already concluded in the remanded matter by the Tribunal, wherein directions were very specific and the Ld. Adjudicating authority was only required to examine the Certificate issued by the Senior Manager Accounts (Indirect Taxation) on behalf of TSL since it was not submitted before the Ld. Adjudicating authority during adjudication. - AT....