In Brief
ITC Limited challenged the Commissioner of Central Excise's rejection of its refund claim involving multiple customs duty assessments across several years. The Supreme Court held that a refund claim cannot be entertained directly without first successfully appealing the original assessment order and obtaining a modification. The Court clarified that an officer considering a refund claim cannot sit in appeal over or review an assessment. An endorsement on a bill of entry constitutes a valid order of assessment. Refunds require that the underlying assessment be modified through proper appellate procedures within the statutory limitation period. The appeal was disposed accordingly.
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