Revenue Cannot Challenge Final Refund Orders or Initiate Recovery u/s 28 for Alleged Erroneous Refunds.

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....Recovery of Refund - The original orders passed by the adjudicating authority in sanctioning the refunds in favour of the appellants were not challenged by Revenue before the Commissioner (Appeals). Therefore, with regard to those two adjudication orders, the matter has attained finality and the question of maintainability of the refund claims cannot be questioned by Revenue at a subsequent stage, by initiating proceedings under Section 28 ibid, for recovery of the refund amounts, considering the same as erroneous refund - AT....