Authorities can't challenge Development Commissioner's bunching of products under HS code for DTA sale.

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....The court held that the revenue authorities cannot question the decision of the Development Commissioner regarding bunching of products for domestic tariff area (DTA) sale within the six-digit Harmonized System (HS) code. In light of the judgments in Ginni International Ltd. and Virlon Textile Mills Ltd., the revenue cannot go beyond or behind the Development Commissioner's decision. The court found no provision in Section 3(1) of the Central Excise Act, 1944, or Rule 100(A) of the Central Excise Rules, 1944, that empowers the revenue authorities to challenge the Development Commissioner's decision. Consequently, the court dismissed the appeal.....