Appellants paid full tax under VCES 2013; no refund eligible per Section 109, appropriation is a formality.

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....Validity of dropping of demand - As such there was no way that Commissioner could have confirmed a lesser amount than the amount paid by the appellants. Moreover, the appellants have paid 100% tax under VCES 2013; the payment was not rejected by designated authority and in terms of section 109 of VCES 2013, the assessee is not entitled for any refund. Under the circumstances appropriation of duty is an empty formality. - AT....