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2014 (2) TMI 852

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..... ices produced by the assessee did not incorporate therein the element of SAD. The adverse findings recorded against the assessee appear to be consequential to lack of correlation and are not based on to total rebuttal of the assessee’s contention. In this view of the matter, we take into account the consistent claim of the appellants to have paid more duty than the sum total of CVD and SAD paid on .....

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..... authority to have been cleared as such without reversal of the CENVAT credit taken of SAD . Before the investigating and adjudicating authorities, the appellants pleaded that the goods imported by them were not removed as such but removed only after manufacturing process. Apparently, this claim could not be proved by the appellants for want of necessary correlation between the Bill of Entry partic .....

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..... n record. Some of the documents produced by the appellants to correlate the duty particulars mentioned in the Bills of Entry with those mentioned in the domestic sale invoices are also seen referred to in the show-cause notice vide para 11.1 and para 11.2. The allegation in the show-cause notice is that no element of SAD was separately shown in the invoices and hence the same should be paid by the .....

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