Binding nature of departmental instructions vs natural justice: tribunals may prioritize procedural fairness over monetary thresholds.
The CESTAT held that CBIC instructions bind departmental officers but do not bind courts and tribunals, which must safeguard natural justice. The Tribunal found the appellate order defective for failing to remit valuation reassessment to the proper officer as statutorily required, treated related Bills of Entry as a single transaction for monetary limit calculation, and invoked its procedural power to hear departmental appeals on merits despite the Board's monetary threshold.