Calcutta HC says Appellate Authority Cannot Travel Beyond the SCN

The taxpayer's refund claim of ₹49.60 lakh was initially rejected on the ground that manual shipping-bill records were not available in ICEGATE. In appeal, additional grounds under Rules 96A, 96B and 89(4)(c) were introduced, without these forming part of the SCN; the High Court held that the taxpayer was denied an opportunity to meet those allegations and ordered fresh adjudication.