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2007 (12) TMI 166 - CESTAT, MUMBAIOnce the assessment has been finalised it becomes an appealable order & in case if there is non-challenge of an appealable order then the question of challenging the correctness of assessment does not arise – demand raised in SCN without challenging the assessment order in appeal - Since demand cannot be raised without challenging the assessment in appeal, the plea whether Sec. 28 gives the power of review of assessment or not can be considered only at the time of final hearing – stay granted
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