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Showing 261 to 280 of 1070 Records
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2013 (5) TMI 815
Issues involved:
The appeal against the confirmed demand and penalty u/s customs duty on illegal import of polyester yarn and polyester cotton yarn from Nepal without discharging customs duty.
Summary:
The appellant appealed against the confirmed demand of &8377; 12,78,627/- and penalty of &8377; 5 lakhs for illegal import of polyester yarn and polyester cotton yarn from Nepal without paying customs duty. The investigation started in 1994, with statements recorded in 1995, and a show cause notice issued in 2003. The adjudicating authority found the demand of &8377; 98.38 lakhs not sustainable, leading to the confirmed demand of &8377; 12,78,627/- and penalty. The appellant argued that the show cause notice was time-barred and the confirmed demand was illegal. The department supported the impugned order.
Upon review, it was found that the demand proposed in the show cause notice was not sustainable at &8377; 98,38,238/-. Therefore, any amount paid by the appellant during investigation should be refunded entirely as the proposed demand was not upheld. Consequently, no penalty is leviable on the appellant. The impugned order confirming the demand and penalty was set aside, and the appeal was allowed with consequential relief.
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2013 (5) TMI 814
Issues: Misdeclaration of goods for drawback claim u/s Customs Act, 1962.
The appellant, M/s. ISGEC Heavy Engineering Ltd., filed a shipping bill for export of goods declaring them as "Turbo Generators - partial shipment consisting of Gearboxes" under classification RITC 8483 40 00, claiming drawback at 2% of FOB value. However, it was found that the goods were classifiable under 8483 99 for a drawback rate of 1%. Due to this incorrect declaration, the goods were held liable for confiscation u/s 113(i) and (ii) of the Customs Act, 1962. The appellant was given an option to redeem the goods by paying a fine of Rs. 1.50 lakhs u/s 125 and a penalty of Rs. 1 lakh u/s 114. The lower appellate authority upheld the decision with a slight reduction in fines. The appellant appealed against this decision, arguing that there was no wilful misdeclaration, citing a mistake in quoting the drawback schedule serial number. The appellant relied on a Supreme Court decision to support their case. The Authorized Representative for the Revenue reiterated the lower appellate authority's findings.
The Tribunal observed that the appellant had correctly described and classified the goods for export but made a mistake in quoting the drawback schedule serial number. As there was no wilful misdeclaration, the Customs authority should verify the appellant's claim for drawback. Referring to the Supreme Court decision, the Tribunal held that claiming exemption based on a genuine belief does not constitute misdeclaration. Since the appellant provided correct particulars about the goods, the question of confiscation and fines did not arise. The appeal was allowed, and the bank guarantee was to be discharged and returned immediately.
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2013 (5) TMI 813
Issues involved: Interpretation of penalty under section 78(5) of the Rajasthan Sales Tax Act, 1994 based on the completeness of declaration form ST 18-A and supporting documents.
Summary:
The revision petition was filed by the petitioner-Department challenging the Tax Board's decision upholding the Deputy Commissioner (Appeals) order, which stated that penalty under section 78(5) could not be imposed if the declaration form ST 18-A was found blank or incomplete, provided other supporting documents were in order. The petitioner cited previous apex court rulings supporting their stance. However, the court considered principles of natural justice and past judgments, remanding similar cases for fresh assessment. Consequently, the revision petition was partly allowed, quashing the previous orders and restoring the matter to the assessing authority for a fresh decision on the penalty proceedings within six months, ensuring the respondent is given a fresh hearing opportunity. A copy of the order was to be sent to the respondent-assessee.
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2013 (5) TMI 812
The Revenue sought a stay on an order for auditing of a Bill of Entry due to non-compliance with Customs Act, 1962. The Tribunal found no reason to interfere and dismissed the stay applications. (Case: 2013 (5) TMI 812 - CESTAT MUMBAI)
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2013 (5) TMI 811
Issues involved: Challenge to garnishing order, non-receipt of assessment order, right to appeal, presumption of service.
Challenge to Garnishing Order: The petitioner challenged the garnishing order issued by the respondent on the grounds of not being served with the assessment order, which was alleged to have been passed on a specific date.
Non-Receipt of Assessment Order: The respondent claimed that the assessment order was sent via speed post, supported by entries in the dispatch register and a receipt generated by Pre-printed Barcode. A presumption of receipt was argued due to the recognized method of sending the post.
Right to Appeal: The petitioner contended that the presumption of receipt is rebuttable, highlighting the non-receipt of the post and the subsequent supply of the assessment order along with the counter affidavit. The petitioner sought to appeal based on the copy of the assessment order provided.
Presumption of Service: Considering the settled legal position in various authorities and courts in India, the Court held that the petitioner had been supplied with a copy of the assessment order along with the counter affidavit. The Court allowed the petitioner to prefer an appeal within 15 days.
Decision: The Court directed the petitioner to prefer an appeal within 15 days, with the appellate authority having the discretion to pass interim or final orders. If the appeal is not heard on merit, the appellate authority must consider the prayer for interim relief promptly and decide within 15 days. The garnishing order was stayed until the petitioner's application for interim relief was decided by the appellate authority. The writ petition was allowed accordingly.
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2013 (5) TMI 810
Issues involved: Export of prohibited item under guise of permissible item, Confiscation of goods, Imposition of penalty without license for export.
Summary:
Issue 1: Export of prohibited item under guise of permissible item
The appellant exported Potassium Chloride under the guise of non-fertilizer grade, but it was found to be fertilizer grade, a prohibited item under Section 11 of the Customs Act. The goods were seized as they did not have a license to export fertilizer grade Potassium Chloride. The test report confirmed the goods were fertilizer grade, leading to absolute confiscation under Section 113(d) of the Customs Act and imposition of a penalty of &8377; 9 lakhs under Section 114(i).
Issue 2: Confiscation of goods
The Deputy Chief Chemist's test report conclusively established that the exported goods were indeed fertilizer grade Potassium Chloride. Despite the appellant's claim of inconclusiveness due to missing details like particle size and sodium content, the report was deemed sufficient. The absence of export documents from the previous exporter, M/s. Delcray Cables Pvt. Ltd., further weakened the appellant's position. The Tribunal upheld the confiscation under Section 113(d) and the penalty under Section 114(i).
Issue 3: Imposition of penalty without license for export
The appellant's argument of being unaware of the goods' prohibited nature due to reliance on the previous exporter was dismissed. The Tribunal cited precedent that exporting restricted items without a license constitutes export of prohibited goods under the Customs Act. The imposed penalty of &8377; 9 lakhs was considered reasonable, well below the permissible limit of three times the goods' value. Attempted export in contravention of law still attracts liability to confiscation and penalty, as established in previous Tribunal cases.
In conclusion, the Tribunal found no merit in the appeal, leading to its dismissal, upholding the confiscation of goods and the penalty imposed on the appellant.
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2013 (5) TMI 809
Search and arrest of person – Seizure of goods – Non-compliance – Whether accused was liable to be acquitted on grounds of non-compliance of Section 42, 50, 55 and 57 of NDPS Act, 1985 – Held that:- P.W. 8 received secret information and recorded same vide Exh. P-21 and also communicated to Dy. SP, Crime Branch – P.W-2 and P.W-8, specifically deposed that Dy. SP, Crime Branch reached house of appellant and joined in search party and search was made in presence of Dy. SP, Crime Branch – Thus section 42 was complied with – P.W-8 took consent of appellant, but did not informed about accused legal rights under Section 50 – As search was made in house of appellant, therefore as per settled legal position, Section 50 of Act, 1985 would not be applicable – Evidences of P.W-8, 9 and 10 revealed that after seizure of contrabands, samples were prepared 1-1/2 months after seizure – P.W-7 deposed that he received only 16 packets of samples without sealed condition – No evidence explaining delay regarding preparation of samples –Therefore, FSL report cannot form basis of conviction of appellant – Appellants Conviction order set-aside – Appeal allowed – Decided in favour of Appellant.
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2013 (5) TMI 808
Denial of exemption claim Notification No. 25/2005, dated 1st March, 2005 and Notification No. 21/2002, dated 1st March, 2002 and Notification No. 69/2004, dated 9th July, 2004 - Penalty u/s 114A and 114AA - Held that:- RBI which is the statutory governing body for use of ATM has clarified that in addition of cash dispensing ATM may have many services/facilities enabled by the bank owning the ATM such as account information, cash deposit, regular bill payment, purchase of reload vouchers for mobiles, mini/short statement and loan account enquiry etc. Therefore, there is no room for any doubt on the proposition that a machine which functions as automatic cash dispenser/bank note dispenser would qualify to be an ATM if it provides the customer of bank the facility of assessing their account not only for dispensing cash but also to carry out any other financial and non-financial transaction. The said meaning given by RBI to an ATM machine has also been applied by RBI under its Master Circular dated 2-7-2007, which is applicable to all computerized machines having facility of accessing the bank account for dispensing cash and to carry out other financial and non-financial transactions as ATMs, irrespective of whether they do have the facility to accept cash/cheques deposit or not.
Appellant has declared the impugned machine as ATM on the understanding as per Circular No. 41/2002 which clarified that “the office equipments referred to above are understood separately and have distinct functions. Cash dispensers are basically machines which can only dispense cash at the valid request of the customers of the bank while ATMs are more sophisticated machines which not only dispense cash but also perform other banking transactions like depositing cash, collecting cheques, bill payments, fund transfers, etc. - mere absence of one faction such as ‘deposit of cash/cheque’ would not be decisive to ascertain whether a machine is an ATM or a cash dispenser for the purpose of extending exemption. - Only to deny exemption under Notification which is available to ATM of Heading 8472.90, the HSN can’t be restrictively interpreted to construe that apart from the main function of dispersing cash, all the functions, as listed therein shall also necessarily be present simultaneously to construe a machine as an ATM.
If the machine Procash 1500Xe is having the facilities such as cash dispencing, fund transfer, bill payment, balance enquiry, mini statements, pin change, etc. but not having the facility of cash/cheque deposit shall be termed as ATM. - Impugned order is set aside - Matter remanded back - Decided in favour of assessee.
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2013 (5) TMI 807
Benefit of duty exemption under serial No. 230 of Notification No. 21/2002-Cus., dated 1-3-2002 - violation of condition No. 40(b) - confiscation of the goods imported - penalties under Sections 112(a)/(b) and 114A - Held that:- Since the contract was terminated vide letter dated 26-4-2007, all the materials, plant, equipment, etc. became the property of the employer. This included the imported equipment on which the JV had availed customs duty concession subject to fulfilment of post importation condition. The goods were imported on 26-3-2003 and the five year period for use and possession by the importer expired only on 25-3-2008. However, with the termination of the contract on 26-4-2007, the importer JV alienated the imported equipment and it became the property of CHPRCL before the stipulated period of 5 years. The condition of importation was that the importer shall use the imported equipment for construction of roads and he shall not sell or otherwise dispose of the imported equipment in any manner. Though there was no sale, the imported equipment became the property of CHPRCL due to default of contract by the importer JV. Thus the condition of exemption stood violated and consequently, the goods became liable to confiscation under Section 111(o) of the Customs Act. Therefore, the confiscation of the imported equipment by the adjudicating authority under Section 111(o) cannot be faulted as the same is sustainable in law.
Once the goods are confiscated under Section 111, the question of option to redeem the same on payment of fine automatically arises, if the goods are not prohibited. In the present case, the goods are not prohibited and hence, option of redemption on payment of fine has to be necessarily given - assessable value of the goods declared was ₹ 1,87,25,400/- and the cum duty value works out to ₹ 2,82,37,903/-. For depreciation purposes, the normal life of a machinery is taken as 10 years. Therefore, the value of the machinery at the time of its acquisition by CHPRCL and its subsequent seizure would have come down substantially. Besides, the machinery was not acquired in a commercial transaction of purchase or sale and therefore, the question of a profit margin while deciding the quantum of redemption fine also would not arise - Penalty imposed is also reduced - Decided partly in favour of appellants.
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2013 (5) TMI 806
Duty demand - Demand of interest - Waiver of pre deposit - Tribunal asked for 25% of duty demand - Held that:- no case has been made out so as to make interference in the impugned order passed by the CESTAT which has not been interfered with by the learned Single Judge. The order is a discretionary one and when facts and circumstances of the case have been considered by the learned Single Judge, in our opinion, such interim order does not call for interference by way of judicial review by this Court. We find no illegality in the impugned order passed by the learned Single Judge. No perversity or patent illegality is apparent in the order passed by the CESTAT. - It makes obligatory on the appellant to deposit the duty or penalty, pending the appeal, failing which the Appellate Tribunal is fully competent to reject the appeal. Right to appeal is neither an absolute right nor an ingredient of natural justice, the principle of which must be followed in all judicial and quasi-judicial adjudication. The right to appeal is a statutory right and it can be circumscribed by the conditions in the grant. The proviso to Section 129E gives discretion to the authority to dispense with the obligation to deposit in case of undue hardship. However, discretion must be exercised on relevant materials and exercised in a bona fide and objective manner. In case there is no undue hardship, High Court should not interfere in judicial review. - However, time to make the re deposit is extended - Decided partly in favour of assessee.
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2013 (5) TMI 805
Waiver of pre deposit - Banking and other Financial Services - Held that:- On a prima facie analysis of the material on record, considered in the context of the definition of the taxable ‘banking and financial services’ read with the provisions of Section 65(105)(zm), we find no infirmity in the adjudication orders warranting grant of waiver of pre-deposit and stay of proceedings pursuant to the adjudication orders impugned - assessee shall pre-deposit the liability as assessed by the three adjudication orders, within six weeks Partial stay granted.
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2013 (5) TMI 804
Waiver of pre deposit - Site Formation and Clearance, Excavation and Earthmoving and Demolition - Held that:- assessee executed the work for SRFDCL works of construction of diaphragm wall; special fill for guide fund; concrete for anchor slab and RCC Hume Pipe and Box Culvert. Whether this activity falls within the taxable service defined under Section 65(97a) and 65(105)(zza) requires detailed examination at the time of final hearing of the appeal. While the main focus in the analysis in the adjudication order appears to reject the assessee’s claim for availing benefit of the exclusionary clause in Section 65(97a) qua which it is claimed that services provided by the assessee to SRFDCL fall within the extended services provided in relation to restoration of water resources or water bodies. On prima facie analysis it does not appear that the services provided by the assessee are comprised within the definition of “Site Formation and Clearance, Excavation and Earthmoving and Demolition” services. - strong prima facie case in favour of the assessee entitling waiver of pre-deposit and stay of further proceedings which are accordingly ordered. There shall be no recovery initiated for the adjudicated amounts pending disposal of the appeal - Stay granted.
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2013 (5) TMI 803
Waiver of pre deposit - Mis-declaration and fabrication of documents - Held that:- appellant had made supply of the goods through cenvatable invoices to the extent of 11% to 58% and the peak thereof was nearly 30% in respect of fabricated documents. When the peak supply in average is 30%, the appellant in both stay applications should be directed to make pre-deposit as contributory to the loss of revenue because the appellant manufacturer had used the false and fabricated cenvatable invoices issued by the appellant. - Decided against assessee.
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2013 (5) TMI 802
Entitlement to deduction under section 80P(2)(a)(iii) - Whether a Co-operative Society, engaged in the business of manufacture and sale of sugar out of the sugarcane grown by its member, can be denied deduction u/s 80P(2)(a)(iii) on the ground that proceedings involves use of power? - Held that:- In view of the said ratio laid down in CIT Vs. Ramco International (2008 (12) TMI 413 - Punjab and Haryana High Court), we are of the view that the claim of deduction made by the assessee under section 80P(2)(a)(iii) of the Act is to be considered in the present facts and circumstances of the case, even though the assessee had raised said claim by way of letter dated 15.12.2004 and had not furnished any revised return of income. The assessee had raised the issue before the CIT (Appeals) and even before us.
Further the issue on merits had been decided in favour of the assessee by the Full Bench of the Hon'ble Punjab & Haryana High Court (supra). Further the appeals filed by the assessee against the earlier appeals dismissed by the Division Bench of the Hon'ble Punjab & Haryana High Court were decided by the Hon'ble Apex Court in Morinda Co-op. Sugar Mills & Ors. Vs. CIT, Chandigarh [2012 (9) TMI 847 - SUPREME COURT] and it was held that the claim of the assessee whether the process undertaken by it was manufacturing or not, it had to be tested on the principle laid down in the case of CIT Vs. Oracle Software India Ltd. [ 2010 (1) TMI 9 - SUPREME COURT OF INDIA (SC)] wherein held the terms ‘manufacture’ implies a change, but every change is not a manufacture, despite the fact that every change in an article is the result of a treatment of labour and manipulation. However, this test of manufacture needs to be seen in the context of the above process. If an operation/process renders a commodity or article fit for use for which it is otherwise not fit, the operation/process falls within the meaning of the word ‘manufacture’.
The Hon'ble Supreme Court in assessee’s own case thus held that The above test has to be applied and adjudicated on case to case basis. It depends on the type of product which ultimately emerges from a given operation. In our view, this aspect has not been examined by the Courts below. The matter was set aside to the file of the CIT (Appeals) with directions to decide and ascertain whether the operation undertaken by the assessee was or was not manufacture. In view of our admitting the claim of the assessee vis-à-vis deduction under section 80P(2)(a)(iii) of the Act and follow ing the ratio laid down by the Hon'ble Supreme Court in assessee’s own case, we remit the present issue also back to the file of the CIT (Appeals) to decide the issue in line with the directions of the Hon'ble Apex Court. Decided in favour of assessee for statistical purposes.
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2013 (5) TMI 800
Demand of differential duty - Valuation u/s 4A - value for the purpose of assessment of physician samples should be arrived on the basis of MRP of trade packs - Held that:- Appellant has not been able to make any case on merits. Accordingly, we direct the appellant to deposit the entire amount of differential duty demanded. At this stage, the learned advocate pointed out that the appellant has pleaded financial difficulty and the appellants have been making loss during the past period and relies on the balance sheet. However on going through the balance sheet, we find that the appellant’s financial position has been improving marginally and further, appellants also have got bank balance and investments, etc. Further it is also seen that they are not making cash losses. In these circumstances, we do not find that the financial difficulties to be so severe that the appellant cannot deposit the differential duty demanded. However, having regard to the claim of financial difficulty and the arguments advanced by the appellant, we consider their request for extended time limit for payment of differential duty favourably and direct the appellant to pre-deposit the differential duty within twelve weeks - Partial stay granted.
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2013 (5) TMI 799
Duty demand - Unavailability of Mixer Log Book - Buffer stock - Held that:- Factory was under production during the two spells for which Mixer Log Books are not available. In such a situation department cannot deny benefit of Modvat credit on PVC resin used in the production. Since exact quantity is not known, in our view certain procedure can be adopted in the instant case to estimate the reasonable quantity of Inputs used. - Based upon this, quantity consumed will be estimated and adjusted in the computation of shortage - explanation and estimated quantity of buffer stock appear to be reasonable, keeping in view the daily consumption of PVC Resin. Department has also not disputed that buffer stock was kept. However demand is from 1-10-1994 to 18-6-1999. Appellant has not adduced any evidence to support that they have started keeping the buffer stock only during this period. Since the practice would be followed even earlier benefit of this factor cannot be extended. - adjudicating authority directed to recompute the difference in quantity keeping in view above and thereafter compute the demand. We also note that department has not produced any evidence about non-receipt of inputs or diversion of inputs but only has stated that there are only two possibilities and the matter pertains to 1994-1999. Appellant has also not been able to give any satisfactory explanation, particularly, in view of the nature of product as also the fact sweepage/spillage waste, lumps, etc., were all already being accounted. Under the circumstances, we do not find any justification to impose penalty under Section 11AC. - Decided in favour of assessee.
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2013 (5) TMI 798
Disallowance of loss of gold and silver due to wastage - CIT(A) deleted the addition - Held that:- It appears from records that the wastage for the assessment year 2004-05 works out to 2.82 per cent. and that for the assessment year 2009-10 is 4.01 per cent. Thus, the wastage claimed by the assessee is within the permissible limit. The learned Departmental representative was also not able to bring any material to controvert the aforesaid factual position. In these facts and circumstances, we find no infirmity in the order of the Commissioner of Income-tax (Appeals) in deleting the addition made by the Assessing Officer by following the order of the Income-tax Appellate Tribunal for the assessment year 2008-09 wherein allowed wastage of 5 per cent. - Decided against revenue.
Depreciation at the rate of 50 per cent. on motor car disallowed - Held that:- On perusal of the assessment order, it appears that the Assessing Officer has given no reason as to why the assessee's claim of depreciation at the rate of 50 per cent. is not allowable. Since the disallowance of depreciation claimed is not supported by any reason, the disallowance so made, cannot be sustained. However, it is seen from the order of the Commissioner of Income-tax (Appeals) that the assessee has purchased the motor car on February 26, 2009 which in other words mean that the asset has been used for less than 180 days and as such the assessee is not entitled for full depreciation but for 50 per cent. of the amount computed. We therefore direct the Assessing Officer to compute depreciation on motor car accordingly.The order of the Commissioner of Income-tax (Appeals) is modified to the extent indicated above. - Decided partly in favour of revenue.
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2013 (5) TMI 797
Recovery of tax deducted at source and interest - CIT(A)directing the AO to wait till finality of the order of the Calcutta High Court for recovery of tax deducted at source and interest - Held that:- The interim order of the hon'ble Calcutta High Court, it is evident that the assessee has opened a separate account for parking the tax deduction at source made by the assessee and the said direction is scrupulously followed by the assessee for all these assessment years. The said direction cannot be ignored in view of the jurisdictional High Court judgment. Therefore, we are of the considered opinion that the direction given in this regard by the Commissioner of Income-tax (Appeals), vide paragraph 5.2 of the impugned order, is fair and reasonable and the same does not call for any interference - Decided against revenue.
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2013 (5) TMI 796
Duty demand - Invocation of extended period of limitation - whether the job workers/processors of fabric were having the knowledge of over-invoicing of the grey fabrics supplied to them by merchant manufacturer or not - Held that:- From the records and during the course of arguments, except from the statement of Dyeing Master, nowhere it is coming out that it was in the knowledge of the processors that the grey fabric is over-valued and invoices issued for grey fabrics, are fake. The dyeing master has nowhere having the knowledge of the valuation of the goods/invoices as he was concerned only with the processing of fabric. Therefore, as it held that was not in the knowledge of the processors that the grey fabric is over-invoiced therefore, the allegation of suppression against the processor is not sustainable. Accordingly, extended period of limitation is also not invokable.
Demand of ₹ 12,52,453/- is not sustainable against the processors as they have cleared the goods to M/s. Pristine Exports under bond and CT-3 certificate. It was also not in processor’s knowledge that their goods shall be diverted in the local market although M/s. Pristine Exports. For violation of bond, M/s. Pristine Exports has paid duty thereon. Therefore as duty has already been paid by M/s. Pristine Exports, the same is not sustainable against the appellant/processors. As duty demand is not sustainable, therefore, penalty is also not imposable on the appellants as the allegation of suppression against the processors have already been set aside.
Provisions of Rule 13 shall apply to the person who has taken the credit. Admittedly in this case the merchant exporters have not taken the credit but deemed credit has been taken by the processing units. Therefore, provisions of Rule 13 are not applicable to the merchant exports in this case.
Penalty is imposable on a producer or manufacturer or registered person of warehouse or a registered dealer. Admittedly, in this case the learned Commissioner has not hold the merchant exporter as producer as manufacturer or registered person of warehouse or a registered dealer. As in the case of C.C.E., Delhi v. Balaji Trading Co. & Ors. - [2013 (1) TMI 502 - DELHI HIGH COURT ] the Hon’ble High Court of Delhi held that the respondents were neither producers nor registered person of a warehouse. That the respondents are not also not registered dealer. That being the case, no penalty is imposable on the said respondent. Therefore, following the decision of Balaji Trading Co. & Ors. (supra), we set aside the penalty imposed on the merchant exporter under Rule 25 of the Central Excise Rules, 2002. - Decided in favour of assessee.
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2013 (5) TMI 795
Denial of rebate claim - Respondents had neither exported the goods within the period of six months from the date of clearance from the factory premises nor have produced any permission from the competent authority for extension of such time limit - Held that:- Goods are to be exported within 6 months from the date on which they are cleared for export from factory. The Commissioner has discretionary power to give extension of this period in deserving and genuine cases. In this case in fact such extension was not sought. It is obvious that the applicants have neither exported the goods within prescribed time nor have produced any extension of time limit permitted by competent authority. The said condition is a statutory and mandatory condition which has to be complied with. It cannot be treated as an only procedural requirement. - rebate claim is not admissible to the respondents for failure to comply the mandatory condition of Notification No. 19/2004-C.E. (N.T.), dated 6-9-2004. The respondents have categorically admitted that goods were exported after six months’ time. - Decided in favour of Revenue.
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