TMI Blog2011 (7) TMI 354X X X X Extracts X X X X X X X X Extracts X X X X ..... equired to be added in the assessable value of the final product on pro-rata basis - It is also not very clear as to whether the demand stands raised and confirmed on the total value of the patterns or by adding the cost of the same in the final product on pro-rata basis - Appeal is allowed by way of remand to adjudicating authority - E/2986 of 2006 - - - Dated:- 5-7-2011 - Mrs. Archana Wadh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e a separate bill for the cost of the same. 2. The demand in the present appeal relates to the said patterns/ moulds/ dies, which were got manufactured by the appellants from the other manufacturers and cost of the same was recovered by them from their buyers. It is seen that the demand stands raised by taking into account the value of the said patterns as if the same were manufactured by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e in the final product on pro-rata basis. We also note that the limitation aspect does not stand dealt with by the lower authorities by taking into account the overall facts and circumstances of the case and the plea of the appellants that the figures of sale of patterns having not been picked up by the Revenue from the balance sheet, which is a public document, no malafide can be attributed to th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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