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Showing 281 to 300 of 703 Records
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2009 (10) TMI 724
Issues:
1. Recovery of Central Excise duty and Education Cess for default in payment.
2. Levying of interest under Rule 8 for delayed payment of duty.
3. Imposition of penalties under Rule 25 and Rule 27 for various violations.
Issue 1: Recovery of Central Excise Duty and Education Cess:
The appellant, engaged in manufacturing excisable goods, failed to pay duty for the period from January to December 2005. The original authority ordered the recovery of duty amounting to Rs. 3,27,708/- along with Education Cess. The appellant contested these demands, leading to an appeal. The Tribunal upheld the duty recovery and Education Cess payment.
Issue 2: Levying of Interest under Rule 8:
The original authority imposed interest at the rate of Rs. 1,000/- per day for the period January to March 2005 and 13% per annum for April to December 2005 under Rule 8. The appellant challenged the daily interest rate. Referring to a High Court judgment, the Tribunal set aside the interest at Rs. 1,000/- per day but upheld the interest at 13% per annum as per Section 11AB of the Act.
Issue 3: Imposition of Penalties under Rule 25 and Rule 27:
Penalties were imposed under Rule 25 for short payment of duty and under Rule 27 for various violations, including non-filing of returns and incorrect details. The Tribunal reduced the penalty under Rule 25 from Rs. 30,000/- to Rs. 10,000/- due to financial hardships but set aside the penalties imposed under Rule 27 as they were beyond the scope of the show cause notice.
In conclusion, the Tribunal disposed of the appeal by affirming the liability to pay interest at 13% per annum on belatedly paid duty and a reduced penalty of Rs. 10,000/- under Rule 25. These payments were directed to be made within 30 days from the date of receipt of the order.
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2009 (10) TMI 723
Issues involved: Delay in payment of duty, confirmation of demand for interest, imposition of penalty, non-compliance with stay order, communication of order to the appellants.
Delay in payment of duty: The appellants, engaged in processing man-made fabrics, faced proceedings for delayed payment of duty under the compounded levy scheme. An interest amount of Rs. 6,050/- was confirmed, along with a penalty of Rs. 6,20,000/- under the relevant rules.
Non-compliance with stay order: The appellants failed to comply with the direction to deposit Rs. 2,00,000/- by a specified date, leading to the rejection of the appeal for non-compliance with the stay order. However, a writ petition before the Hon'ble Gujarat High Court resulted in directions for the appeal to be heard without requiring any pre-deposit.
Communication of order: The appellants claimed they received no communication from the department regarding the final order until a letter for recovery of dues was received in 2009. The department failed to prove the delivery of the order, and the appellants argued that dispatch by registered post does not constitute valid communication u/s 37C of the Central Excise Act, citing a Tribunal decision.
Decision: The Tribunal found that the department could not prove the appellants received the order, considering the appeal as filed within time. The impugned order was set aside due to the directions of the Hon'ble High Court, remanding the matter to the Commissioner (Appeals) for further proceedings in accordance with the High Court's directives.
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2009 (10) TMI 722
Issues: Imposition of penalty under Section 114(iii) of the Customs Act, 1962
Analysis:
1. The appellant, engaged in shipping broker/forwarder services, appealed against a penalty of Rs. 2 lakhs imposed under Section 114(iii) of the Customs Act, 1962. The case involved the appellant's role in arranging delivery orders for shippers and forwarding necessary documentation to the shipping line for export purposes.
2. The appellant's advocate argued that the appellant's responsibility was limited to providing delivery orders to shippers and forwarding necessary documentation to the shipping line. The advocate highlighted the appellant's diligent actions in ensuring proper documentation before loading containers onto vessels. The appellant had communicated with the shipping line regarding the status of shipping documents and had clearly instructed not to load containers without the required documentation.
3. Upon hearing the case, the judge found that the appellants had been diligent in their duties and had explicitly informed the shipping line not to load containers without the necessary documentation, specifically the Let Export Order (LEO). The judge criticized the original adjudicating authority for incorrectly attributing fault to the appellants for instructing the shipping line to load the consignment without the LEO. The judge concluded that the appellants were not at fault and set aside the penalty, allowing the appeal with consequential relief, if any.
4. The judgment emphasized the importance of clear communication and adherence to proper documentation procedures in the shipping process. It highlighted the appellant's proactive approach in ensuring compliance with export requirements and refuted the allegations of negligence or wrongdoing. The decision served as a reminder of the need for accuracy and diligence in customs-related activities to avoid unwarranted penalties.
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2009 (10) TMI 721
Issues:
1. Restoration of appeal due to non-clearance from Committee on Disputes.
2. Stay of recovery of duty amount raised under Customs Act, 1962.
3. Valuation of bulk liquid cargo suffering losses in transit on import into India.
4. Assessment of assessable value based on actual payment for importing consignments of crude oil.
Issue 1: Restoration of appeal
The appellant, a PSU, filed a restoration application for its appeal which was dismissed earlier due to non-clearance from the Committee on Disputes. The Revenue verified the cause and found it to be correct, leading to the restoration of the appeal to its original number.
Issue 2: Stay of recovery of duty amount
The appellant sought a stay of recovery of duty amount of Rs. 13,29,722 raised under the Customs Act, 1962. The issue revolved around the valuation of bulk liquid cargo facing losses in transit on import into India. Specifically, the question was whether the payment made by the importer for the Bill of Lading quantity and actual freight incurred should be adopted for arriving at the assessable value.
Issue 3: Valuation of bulk liquid cargo
The first appellate authority ruled against the assessee, stating that the quantity received in shore-tank is immaterial, and the entire quantity of the bulk liquid should be considered for adjudication. The demurrage charge was also deemed part of the transaction value, which was contested by the appellant.
Issue 4: Assessment of assessable value
The Adjudicating Authority applied Section 14 of the Customs Act, 1962 along with Rule 9(1) of Customs Valuation Rules, 1988 to determine the assessable value. It held that the amount actually incurred by the importer for importing each consignment, including FOB value and freight, represents the transaction value for levying ad valorem duty. The appellant failed to succeed before the appellate authority, with both authorities basing their decisions on relevant circulars and court decisions. The appellant was directed to make the pre-deposit of the duty demanded within a specified timeline to protect the interest of Revenue.
This detailed analysis of the judgment covers the issues of restoration of appeal, stay of recovery of duty amount, valuation of bulk liquid cargo, and assessment of assessable value, providing a comprehensive understanding of the legal proceedings and decisions involved in the case.
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2009 (10) TMI 720
Issues involved: Stay petition against waiver of pre-deposit amounts u/s 11A(1) of Central Excise Act, 1944, interest u/s 11AB, penalties u/s 11AC, Rule 25, and Rule 27.
Demand Confirmation: The Adjudicating Authority confirmed demands against the appellants due to reworking material cost to include transportation and other expenses till raw material reaches job worker's premises.
Appellant's Submission: The appellants, engaged in manufacturing motor vehicles, argued that the value for duty liability on body building should be based on Net Dealer's Price without additional expenses like freight and insurance, citing precedents.
Revenue's Argument: Revenue contended that all expenses for supplying inputs to the job worker, including transportation costs, should be added to the value based on the Supreme Court's decision in Ujagar Prints case.
Tribunal's Decision: The Tribunal found that the demand was confirmed due to the appellant not considering additional expenses in the cost of inputs. As the appellant is a job worker, Section 4(1)(b) applies for assessable value, and duty paid by TML is based on Central Excise Valuation Rules.
Assessable Value: The assessable value of final products cleared by the appellant should be based on the cost of inputs received by TML, which was correctly considered. The Tribunal noted that the appellant made a prima facie case for waiving the pre-deposit amounts, and the condition for pre-deposit was waived until the appeal's disposal.
Conclusion: The Tribunal granted the waiver of pre-deposit amounts and stayed the recovery pending appeal disposal. The judgment was pronounced in open court on 23-10-2009.
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2009 (10) TMI 719
Issues:
Violation of provisions of CHALR, 2004 leading to forfeiture of security deposit.
Analysis:
The appeal was filed by a Customs House Agent (CHA) against the order forfeiting Rs. 2000 from their security deposit for breaching the provisions of CHALR, 2004. The case revolved around the death of a partner in the CHA firm, which was duly communicated to the Department. The CHA was granted a six-month period to complete formalities, including submitting a new partnership deed. Despite multiple directives to submit required documents, the CHA failed to comply within the stipulated time frame. The violation was based on Regulation 15(1) of CHALR, 2004, which mandates reporting any change in the firm's constitution to the Commissioner of Customs and submitting a fresh application within 60 days from the date of change.
The appellant argued that they informed the department promptly about the partner's death and provided documents as requested, eventually submitting all required documents by 30-5-2006. However, the judge noted that the new partnership deed was executed on 10th January 2006, triggering the 60-day limitation period. Despite being reminded to submit documents on 3-3-2006, the CHA only complied on 30-5-2006, after the lapse of the stipulated 60-day period. Consequently, the Commissioner of Customs rightfully concluded that the CHA failed to meet the deadline for submitting the necessary documents, leading to the forfeiture of the security deposit.
In the final judgment pronounced on 29-10-2009, the judge upheld the decision, finding no fault in the order issued against the CHA for violating Regulation 15(1) of CHALR, 2004. The failure to adhere to the prescribed timeline for submitting essential documents resulted in the forfeiture of the security deposit, as per the regulatory requirements.
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2009 (10) TMI 718
Refund claim - time limitation - Held that: - the protest given by the manufacturer cannot give benefit of extended time for claim of refund and a buyer has to claim the refund within the stipulated time limit prescribed u/s 11B of the CEA - appeal dismissed - decided against appellant.
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2009 (10) TMI 717
Valuation of imported goods - The value of the consignments has been enhanced adopting the, value applicable to defective CRGO sheets based on DOV data - Held that: - the enhancement of value based on DOV data of comparable goods is no doubt an accepted method for customs valuation when the declared value of the goods are not acceptable for valid reasons. However, in the present case the basic dispute is whether or not the goods imported by the Appellant can be considered as defective CRGO sheets.
The materials obtained from dismantled transformers cannot be treated as defective CRGO sheets. Therefore, we do not find any misdeclaration of description by the Appellant in respect of the present consignments. Having held so, the question of applying higher value based on DOV data applicable to defective CRGO sheets also does not arise.
Appeal allowed - decided in favor of appellant.
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2009 (10) TMI 716
Issues:
1. Liability for using common inputs in the manufacture of both dutiable and exempted goods.
2. Merit of the demand and penalty imposed.
3. Time-barred nature of the demand.
Analysis:
Liability for using common inputs:
The appellants appealed against a demand and penalty imposed due to using common inputs in manufacturing both dutiable and exempted goods. The demand was based on Rule 57CC of the Central Excise Rules, holding the appellants liable to pay a percentage of the price of exempted goods. The appellants argued that they had availed credit on the common inputs but the demand far exceeded the credit amount. They contended that the inputs were used at various stages in the manufacturing process of both excisable and exempted goods. The appellants also challenged the sustainability of the demand on its merits.
Merit of the demand and penalty:
The appellants disputed the demand on the grounds that no suppression of facts with intent to evade duty could be alleged against them. They highlighted that they had filed classification lists in 1993 and 1997, duly approved by the proper officer, indicating the manufacturing of exempted goods with nil excise duty liability. The Revenue contended that the appellants suppressed facts by not providing declarations under Rule 57G and failing to submit copies of invoices for the cleared Coal Gas. However, the Tribunal found merit in the appellants' argument regarding the time-barred nature of the demand.
Time-barred nature of the demand:
The show-cause notice was issued in September 2001 for the period September 1996 to August 2000, alleging suppression of facts. The appellants' classification lists from 1993 and 1997, approved by the proper officer, clearly stated the manufacturing of exempted goods with nil excise duty liability. Considering this, the Tribunal concluded that the demand was time-barred. Without delving into the merits, the appeal was allowed based on the issue of time bar, leading to the setting aside of the demand and penalty. The decision was made in favor of the appellants due to the time-barred nature of the demand, and the appeal was allowed accordingly.
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2009 (10) TMI 715
Waiver of pre-deposit - denial on benefit of N/N. 4/2006-C.E., dated 1-3-2006 as amended by N/N. 37/2006-C.E., dated 20-7-2006 - The case of the Revenue is that the concessional rate of duty is in respect of pure, terephthalic acid and the purified terephthalic acid manufactured and cleared by the applicants is having purity of 99.8% - Held that: - The goods manufactured by the applicants is classified under Tariff Heading 2917 36 00 and having purity of 99.8% - The Flow Chart produced by the applicants in respect of their product shows the process of purification and the product in the market is known as Purified Terephthalic Acid (PTA) and there is no stipulation in the Tariff or in the HSN Explanatory Notes as well as the Notification regarding purity of the product - it is a fit case for total waiver of duty and penalty - petition allowed - decided in favor of petitioner.
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2009 (10) TMI 714
CENVAT credit - capital goods - Ziricon Oxygen Probe - Polymer Conductivity Analiser/Censor - Cable Tray - denial on the ground that the same are not specified goods - Held that: - Board’s Circular dated 2-12-1996 clarifies that the components, accessories of the specified goods irrespective of classification are entitled for credit - the goods in question are used as the components of the plant, therefore, in view of the Board’s Circular relied upon by the appellants irrespective of classification, the benefit is available - credit allowed - appeal allowed - decided in favor of appellant.
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2009 (10) TMI 713
The Revenue's appeal was dismissed by the Appellate Tribunal CESTAT KOLKATA as the demand was held to be time-barred due to no suppression on the part of the respondent with intent to evade payment of duty. The goods declared as betel nuts were considered the same as areca nuts, hence wrongly claimed the benefit of notification. The appeal was dismissed.
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2009 (10) TMI 712
Issues:
- Appeal against demand and penalty set aside by Commissioner (Appeals) due to no suppression to evade duty
- Revenue issued show-cause notice invoking extended period of limitation on the ground of suppression
- Commissioner (Appeals) decision based on appellant's declaration in classification list and monthly returns
Analysis:
1. The main issue in this case revolved around the appeal filed by the Revenue against the decision of the Commissioner (Appeals) to set aside the demand and penalty. The Revenue had initially issued a show-cause notice on the grounds of suppression to evade duty for a specific period. The Commissioner (Appeals) based their decision on the fact that there was no suppression of material facts by the respondents with the intent to evade payment of duty, thereby rendering the demand as time-barred.
2. The Commissioner (Appeals) made a detailed analysis of the case, noting that the appellant had declared the hard waste in the classification list, which was duly approved, and had also filed monthly returns regularly showing clearance at a nil rate of duty. The Commissioner observed that the appellant had produced evidence in the form of Xerox copies of the classification lists and RT-12 returns, demonstrating the proper declaration and assessment of the hard waste under the relevant sub-headings. This led the Commissioner to conclude that there was no suppression of facts or misstatement by the appellant.
3. The appellate tribunal, consisting of Shri S.S. Kang and M. Veeraiyan, JJ., upheld the decision of the Commissioner (Appeals) based on the factual findings. The tribunal noted that the Commissioner's finding that the respondents had indeed filed the classification list and monthly returns as required, and that there was no evidence presented to challenge this fact. Consequently, the tribunal found no fault in the impugned order and dismissed the appeal brought by the Revenue.
4. In summary, the judgment highlights the importance of proper declaration and submission of documents by the appellant in tax matters. The case underscores the significance of maintaining accurate records and complying with reporting requirements to avoid allegations of suppression or evasion of duty. The decision ultimately favored the appellant due to the lack of evidence supporting the Revenue's claims of suppression, emphasizing the need for thorough documentation and compliance with regulatory obligations in such legal disputes.
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2009 (10) TMI 711
Valuation - demand on the ground that the goods cleared to the other units of the appellants are to be assessed as per the provisions of Rule 8 of Valuation Rules, 2000 - Held that: - the appellants cleared 99% goods to the independent buyers - Some portion of the production is cleared to the other units of the appellants - reliance placed in the decision of Larger Bench, in the case of Ispat Industries Ltd. v. CCEx., Raigad [2007 (2) TMI 5 - CESTAT, MUMBAI], where it was held that where a part of the production is cleared to the independent buyers, the provision of Rule 8 of the Valuation Rules are not applicable in respect of the goods which are cleared to other units - appeal allowed - decided in favor of appellant.
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2009 (10) TMI 710
Issues:
Appeal against Commissioner's order on duty liability determination and penalties for delayed payment.
Analysis:
The appellants, manufacturers of Re-rolled Products under the Compounded Levy Scheme, challenged the Commissioner's final determination of duty liability for two periods. For the period from September 1997 to March 1998, the Commissioner's final determination was higher than the provisional determination. The appellants paid the differential duty promptly upon receiving the final order, except for a small balance paid late, resulting in a penalty. For the subsequent period in 1998-99, the appellants paid the duty immediately upon receiving the order, but penalties were imposed for delayed payment. The Commissioner (Appeals) upheld the penalties.
The appellant argued that they were not expected to know the enhanced final determination by the Commissioner and that they promptly paid the duty upon receiving the orders. The JDR supported the penalties, emphasizing delayed payments made by the appellants. The Tribunal noted that under the Compounded Levy Scheme, duty payment is based on the Commissioner's determination. The appellants paid the differential duty promptly upon receiving the final order for the first period, except for a small balance paid late, justifying the penalty. For the second period, the appellants paid promptly upon receiving the order, and no delay was found. Consequently, the penalty for the second period was not justified.
The Tribunal allowed the appeal, except for sustaining the penalty of Rs. 7,505.00 for the first period due to the late payment of a small balance amount. The judgment clarified the obligations under the Compounded Levy Scheme and the consequences of delayed payments, ultimately providing relief to the appellants for the second period's penalty.
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2009 (10) TMI 709
Issues:
1. Appeal against demand of duty and penalty set aside by Commissioner (Appeals).
2. Dispute regarding receipt of raw materials by registered dealer.
3. Evidence produced by present respondents to support receipt of raw materials.
4. Revenue's contention of dealer supplying non-dutiable scrap.
5. Payment made by respondents during investigation.
6. Compliance with formalities for availing credit.
7. Findings of Commissioner (Appeals) regarding receipt and use of inputs.
8. Payment to supplier through banking channel.
9. Lack of challenge to findings in present appeal.
10. Absence of reference from supplier regarding invoicing to respondents.
11. Dismissal of appeal by Appellate Tribunal CESTAT KOLKATA.
The Appellate Tribunal CESTAT KOLKATA heard an appeal filed by the Revenue against an order by the Commissioner (Appeals) setting aside a demand of duty and penalty amounting to Rs. 6,71,473. The dispute arose from the Revenue denying credit to the present respondents based on the belief that the registered dealer did not actually receive the raw materials, as indicated by the vehicle numbers on the invoices. The Commissioner (Appeals) found in favor of the present respondents, noting the evidence provided, including RG 23A Part I copies, goods receipt notes, payment of duty, and manufacturing processes. The Revenue contended that the dealer may have supplied non-dutiable scrap instead of raw materials. Despite the respondents making the disputed payment during the investigation, the Tribunal upheld the Commissioner's findings that the inputs were received, used in manufacturing, and cleared with duty payment. The Tribunal also highlighted the lack of challenge to these findings in the appeal, as well as the absence of any statement from the supplier regarding invoicing specifics to the respondents. As a result, the Tribunal found no fault in the impugned order and dismissed the appeal.
This judgment underscores the importance of providing substantial evidence to support claims in tax disputes, as demonstrated by the present respondents producing various documents to establish the receipt and utilization of raw materials. The Tribunal's analysis focused on the factual findings of the Commissioner (Appeals) regarding the compliance with formalities for availing credit, the payment made through a banking channel, and the lack of contradiction in the evidence presented. Additionally, the Tribunal emphasized the significance of the supplier's role in the proceedings, highlighting the absence of any assertion from the supplier regarding the nature of the invoices issued to the present respondents. The dismissal of the appeal by the Tribunal signifies a thorough consideration of the evidence and findings presented before it, ultimately upholding the decision of the Commissioner (Appeals) in favor of the present respondents.
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2009 (10) TMI 708
Issues:
Appeal against rejection of refund claim for duty paid at the time of provisional release of seized yarn.
Analysis:
The appeal pertains to the rejection of a refund claim amounting to Rs. 3,17,139/-, which was paid by the appellant at the time of provisional release of seized yarn under a B-11 bond. The original order of the Commissioner (Appeals) setting aside the confiscation was later overturned by the Additional Commissioner in de-novo adjudication. The Additional Commissioner confirmed the confiscation of the seized goods, which were not physically available for confiscation. Instead, it was ordered that the amount covered by a Bank Guarantee executed by the appellant be appropriated in lieu of confiscation. The appellant claimed ownership of the seized goods and got them provisionally released duty-free, but later failed to prove any contrary facts regarding the non-duty paid character of the goods. The appellant's refund claim was based on the original order of the Commissioner (Appeals), which no longer existed due to the subsequent decision upholding the confiscation after remand by the Tribunal. The appellant's argument that the Deputy Commissioner enhanced the redemption fine by requiring payment of duty under Section 125(2) was deemed meritless. The Tribunal found that the duty liability at the time of provisional release was valid, and since the basis of the refund claim no longer existed, the rejection by lower authorities was upheld. The appeal was consequently rejected.
Conclusion:
The judgment highlights the legal intricacies surrounding the refund claim for duty paid at the time of provisional release of seized goods. The decision emphasizes the importance of legal procedures and the finality of orders in such matters, ultimately leading to the rejection of the appellant's claim.
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2009 (10) TMI 707
Validity of vakalatnama - Held that:- While scrutinizing the vakalatnamas filed, be it in the Registry of this Court, the Subordinate Courts in Delhi or the Tribunals, Authorities and Foras in Delhi, failure/defect in the vakalatnamas, noted in sub paras ‘a’ to ‘e’ of Para 21 of the decision of the Supreme Court in Uday Shankar’s case [2005 (11) TMI 436 - SUPREME COURT], shall be treated as a deficiency in the execution of the vakalatnamas making liable the said vakalatnama to be returned Further, in the situation contemplated by sub paras ‘f’ to ‘i’ of Para 21 of the decision in Uday Shankar’s case, vakalatnamas not executed in the manner indicated in the said sub paras shall also be treated as a deficiency in the execution of the vakalatnama, making liable said vakalatnama to be returned.
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2009 (10) TMI 706
Issues Involved:
Challenge to order for repayment of amount; Claim of mistaken belief in payment of excise duty; Applicability of exemption notification; Transfer of duty burden to customers; Unjust enrichment; Grant of stay of impugned order; Waiver of deposit pending appeal.
Analysis:
The appellants contested the order directing them to repay an amount stated to have been wrongly refunded, arguing that the initial payment was made under the mistaken belief that their product was subject to excise duty, which was actually exempted under Notification No. 56/2002-CE. Reference was made to a previous Tribunal order related to a similar issue for an earlier period. The Department contended that since the duty burden was passed on to customers, the appellants should not be entitled to a refund to avoid unjust enrichment.
Regarding the unjust enrichment issue, it was determined that a decision on this matter should be made after considering all contentions, including the absence of a specific charge in the show cause notice. The Tribunal found that the appellants had made a prima facie case for granting a stay of the order, as the amount to be recovered was the same amount previously refunded erroneously. Therefore, the impugned order was stayed, and the requirement for deposit was waived until the final disposal of the appeal. The demanded amount, interest, and penalty were all waived during this period. It was clarified that these observations were solely related to the stay application, and the application was disposed of accordingly.
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2009 (10) TMI 705
Issues involved:
The appellant claimed a mistake in the final order regarding the consideration of their plea of limitation, seeking a recall of the ex-parte order and a re-hearing of the appeal.
Summary:
1. The appellant pointed out a mistake in Final Order No. A-153/2009/SMB/C-IV, stating their plea of limitation was not considered. The appeal was disposed of on merits without representation from the appellant. The demand for recovery of wrongly taken CENVAT Credit was sustained, but the plea of limitation was not addressed. An amendment allowed the appellant to raise the plea of limitation, which was not considered in the final order. The Tribunal acknowledged the error and decided to rectify it.
2. The Tribunal allowed the appellant to raise the plea of limitation through an amendment, which was not considered in the final order. The show-cause notice did not invoke the extended period of limitation, making the demand time-barred. The appellant's plea of limitation involved mixed questions of fact and law. The Tribunal held that the plea raised for the first time before them, without supporting facts raised earlier, cannot be entertained. The Tribunal clarified that allowing the amendment of the memorandum of appeal does not guarantee a favorable decision.
3. The Tribunal partially allowed the application, inserting a new paragraph addressing the plea of limitation between the relevant sections of the final order. The final order was amended accordingly. The Tribunal emphasized the importance of raising necessary facts to support legal pleas at the appropriate stage, stating that the plea of limitation raised before them for the first time was not maintainable.
4. The final order passed by the Tribunal was amended to include the new paragraph addressing the plea of limitation. The Tribunal disposed of the application accordingly.
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