TMI Blog2014 (6) TMI 272X X X X Extracts X X X X X X X X Extracts X X X X ..... tivities of M/s.SISCOL. An agreement should also be examined with actual state of affairs and its implementation from the records. In the present case, it may be seen from the documents and records that in 2004, M/s.SISCOL was declared as sick unit under SICA, 1985. CDR Cell report would show that SJG came forward for financing the sick unit M/s.SISCOL, as finance acts as an engine of growth. It appears from the Show Cause Notices that M/s.JSWPL, one of the companies of SJG, have expertise in constructing and operating Power Plants and M/s.JSW Steel Ltd. another company of SJG, is one of the purchasers of the final product of M/s.SISCOL. It is recorded in the CDR Cell report that there was proposal of merger of M/s.SISCOL with SJG, which is corroborated by Director's report dt. 26.4.2005 of JSWPL balance sheet. It is mentioned in "Unit III Debentures Trust Deed" dated 22.9.2005 of M/s.JSWPL that with a view to finance its 2 x 30 MW plant at SISCOL, the company has approached the Debenture holders. JSWPL declared to TNEB by letter dated 6.1.2005 that Captive Power Plant is installed inside the SISCOL premises to meet the present and future power requirements of SISCOL. Further, T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ted, as the evidence produced by the appellants were available at the time of adjudication and are very much relevant for arriving at the correct conclusion in the matter. 4. M/ s. JSW Power Ltd. ('JSWPL' - in short) filed an appeal against imposing of penalty of Rs.5,00,00,000/- under Rule 26 of the Central Excise Rules, 2002 read with Rule 15 of the CENVAT Credit Rules, 2004 5. As both the appeals have arisen from a common order and the facts are similar, therefore, both the appeals are heard together and disposed of by a common order. 6. The facts of the case are that the main appellants M/ s.JSWSL are having an integrated steel plant with facilities for production of 'pig iron', 'steel billet', 'bar', 'rod with virgin iron ore' as the basic raw material. 7. The issue in this case mainly relates to CENVAT credit taken by the appellants on the new 'Captive Power Plant' ('CPP' - in short) of 2 x 30 MW set up during the period Sept.'05 to Oct.'06 on a land leased to M/s.JSWPL, for setting up a 'CPP'. 8. Earlier, the main appellants were known. as M/ s.Southern Iron and Steel Company Ltd. ('SI ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... should be received within the factory to take credit. The real manufacturer is only M/ s.JSWPL and as the land is leased out, the owners of the land is M/ s.JSWPL and not M/ s.SISCOL; and (c) Possession of capital goods was with M/s. JSWPL and not with M/S. SISCOL. 11. The adjudication took place and a detailed order was passed confirming the demand of Rs.6,79,61,303/- towards wrong credit availed by M/s.SISCOL and Rs.6,79,61,303/.., towards excise duty as M/s. SISCOL has utilised the credit for the payment of excise duty and equivalent amount of penalty under Rule 15(2) of the CENV AT Credit Rules, 2004 read with Section 11AC on the ground that M/s. SISCOL has suppressed the fact of existence of lease agreement _with M/ s.JSWPL and hence has suppressed fact of non-receipt and non-possession of the capital goods by M/ s.SISCOL. A penalty of Rs.5 crores on M/s.JSWPL was also imposed under Rule 26 of the CENV AT Credit Rules, 2004 on the ground that M/ s.JSwpL not only facilitated M/ s.SISCOL to avail CENV AT credit on capital goods which was not available to them. 12. Aggrieved from the said order the appellants are in appeal before us. 13. The learned counsel Shri Shiva ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ri. -Chennai);and (xiv) M/s.GujaratAmbuja CementsLtd. Vs Commissioner of Central Excise, Chandigarh reported in 2001 (130) E.L.T.129. 16. On the other hand, Shri Alok Shukla, learned JCDR, who appeared on behalf of the Revenue, supported the impugned order and drew our attention to the impugned order. He relied on the decisions of (i) Majestic Auto Ltd. Vs Commissioner of Central Excise, Ghaziabad reported in 2004 (173) E.L.T.145 (Tri.-Del.); and (ii) ChemplastSanmar Ltd. Vs Commissionerof Central Excise, Coimbatore reported in 2004 (177) E.L. T.446 (Tri-Chennai). 17. He also drew our attention to the transfer of lease deed, wherein, the 'lessee' (M/s.JSWPL) .shall be entitled without any inference from the 'lessor' to carry out and conduct its business activities and operation on the 'lessee's land. Therefore, in conclusion, he submitted that as discussed in the impugned order, the appellants are not entitled to take . CENVAT credit on the capital goods received in the leased out premises of M/ s. JSWPL. 18. Heard both sides and considered their submissions in detail. 19. After considering the submissions made by both sides, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... if mines are captive mines and they constitute as one integrated unit together with the concerned cement factory. 23. In this case also, it is countered that the power plant is a 'CPP', which is to be used by the appellants (or manufacturing of their final product. Similar view was also 'taken by the Tribunal in the case of Sanghi Industries Ltd. (supra), wherein the issue was that the CENV AT credit was denied on the premise that 'Light Diesel Oil/Furnace Oil' used ~ power plant situate 12 kms away from the clinker unit entitled to ' credit. The core reason for denial of credit was that the inputs were not used in the factory. However, this Tribunal has held that the assessees are entitled to avail CENV AT credit on inputs/ capital goods although they were not used in the factory, relying on the decision of Haldia Petrochemicals Ltd. (supra) 24. Further, the other allegation against the appellants is that CENV AT credit was also not available as per Rule 4. It is also proposed in the show-cause notice that as per Rule 4 of the CENV AT Credit Rules, 2004 goods may be received within the factory to take credit and the real manufacturer rs M/ sJSWPL and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re acquired by him on lease, hire purchase or loan agreement, from a financing company. (4) The CENVAT credit in respect of capital goods shall not be allowed in respect of that part of the value of capital goods which represents the amount of duty on such capital goods, which the manufacturer or provider of output service claims as depreciation under section 32 of the Income-tax Act, 1961 (5) (a) The CENVAT credit shall be allowed even if any inputs or capital goods as such.. or after being partially processed are sent to a job worker for further processing, testing, repair, re-conditioning, or for the manufacture of intermediate goods necessary for the manufacture of final products or any other purpose, and it is established from the records, challans or memos or any other document produced by the manufacturer or provider of output service taking the CENVAT credit that the goods are received back in the factory witt)in one hundred and eighty days of their being sent to a job worker and if the inputs or the capital goods are not received back within one hundred eighty days, the manufacturer or provider of output service shall pay an amount equivalent to the CENVAT credit att ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... te identity (subsidiary). In the subsidiary, M/ s.SAIL continued to have 98B0/o shareholding and remaining 2B0/o went to National-Thermal Power Corporation ('NTPC' - in short) . In those set of facts, it was argued by the learned counsel for the appellants that the deal was executed for business of restructuring with intent to strengthening M/s.SAIL's core business activity and it was not a case of sale as normally understood. It is also the contention of the learned Counsel that in this case corporate veil was required to be lifted so as to arrive at the reality of the transaction and reach appropriate conclusion. Therefore in that case, this Tribunal has relied on the judgment of the Hon'ble Supreme Court in the case of State of Uttar Pradesh v. V. Renugsagar Power Co. and others reported in 1988 (4) SCC 59 for lifting of corporate veil. It is being explained that the case of T Renusagar Power Co., was one where a dedicated power generation plant was set up to support the aluminium manufacturing actiyio/ of M/s.Hindustan Aluminium Corr Ltd. (M/s. Hindalco - in short) and after going into all the relevant aspects, the Hon'ble Supreme Court ruled that since the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... wer plant was installed in the factory premises of the M/ s.SAIL and it is only the 'CPP' of M/s.SAIL though the ownership of the same was transferred to M/ s.BESCL, a subsidiary of M/ s.SAIL; the entire power generated by M/s. BESCL requires to be sold to M/s. SAIL. In that scenario also, the matter was referred to Larger Bench for decision but the Larger Bench of this Tribunal returned the reference as in the referral order the reasons of difference were not given. Anyhow, the facts of that case are also somehow different from this case. As in this case, M/ s.JSWPL was given the land on lease only for installation of 'CPP', which in turn is to be used by the appellants M/ s. SIUCOL for manufacturing of their final product i.e., iron and steel. There is no sale of electricity by M/ s.JSWPL to the appellants. 30. In this case, the other relevant facts are that for generation of electricity, both the water and steam turbines which are used to produce power, were to be supplied by. M/ s.SISCOL though the boilers, which are also installed in the premises of M/ s.SISCOL. Therefore, ye no stretch of imagination it can be said that 'CPP' for generation of elect ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... en on lease a part of the factory premises of M/ s. Majestic Auto Ltd., who have also sold the machines and equipments on which they have availed MODVAT credit and Ml s. Majestic Auto Ltd., have got manufactured the parts on job work basis from Ml s.Hero Briggs Stratton Auto Pvt. Ltd. In this case, the facts are that a part of the land has been leased out to M/s JSWPL for installation of 'CPP' which is being used by the appellants for manufacturing of their final products. There is no contract between the appellants and Ml s. JSWPL for generation of electricity in the 'CPP' by Ml s.JSWPL and was to be sold to the appellants. In fact, Ml s. JSWPL was leased out land for installation of 'CPP' only. Therefore, the decision in the case of M/s.Majectic Auto Ltd., cannot be relied on in the facts of this case and the decision of Ml s.MajectAuto Ltd. (supra) was also dealt by that Tribunal in the case of Ml s.Steel Authority of India Ltd. - 2007 (219) E.LT.960 (Tri-Dei). Further, we find that the learned JCD also relied on the decision of Ml s.Chemplast Sanmar Ltd. -2004 (177) E.L. T.446 (Tri-Chennai), this Tribunal hold that although Ml s. Chemplast Sanmar Ltd., ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... goods in the factory of the appellant. Appellant seeks approval of credit taken based on liberal Interpretation of rules and further extensions the principles. approved in decisions of the Tribunal and the Courts rather than by a straight interpretation of the Rules. It appears that allowing this credit will lead- to a situation where a manufacturer can take credit of .dutv paid by its neighbor from neighbor's.funds for setting up a power plant so long as at least a part of the power generated is used in the factory of the manufacturer taking credit. Since such a consequence may not be warranted tn the scheme of Cenvat Credit Rules, 2004, I intend to examine this matter by formulating certain issues which have not been stated explicitly in the order recorded by the Judicial Member.The issues as I perceive are the following: I. For taking Cenvat Credit on capital goods is it necessary that the manufacturer taking credit should have paid for the value of the goods and duty on the goods from his funds? IL For taking Cenvat Credit on capital goods, is it necessary that the goods should have been received in the factory of the manufacturer who takes the credit? III. In the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... capital qoods were received in- the factory of SISCOL on the date of taking credit. This is because. of the peculiar facts of this case, SISCOL had leased out to JSWPL 50.14 acres of their factory-land on nominal lease charqes o{ Rs~ldOOO per annum for setting up a power plant, So SISCOL_daimsthatthelandwherethe power plant.wasset up was paffof their factory and hence capita goods were received in their - factory for the purpose of Rule 4 (2a). They also' submit that the power plant was being set up for generating power for use in their factory only. JSWPL set up the plant for the reason that SISCOL did not have the financial capability to set up a power plant at that particular point of time. They also have an argument that judicial decisions support a case for allowing credit even if the capital goods were not inside the factory. 42. Since many decisions are relied upon by the appellant it is necessary to tabulate the facts of the cases involved which is done in the following table. S. No. Reference of case Whether the examined respect Whether the of goods were goods were inputs o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t notwithstanding the fact that the job-worker had not paid the value of the capital goods or excise duty on the capital goods from his funds. Three such cases are,- (i) CCE Vs. Sunrise Chemical Industries-2010 (262) E.L.T.110(Guj); (ii) Prolite Engineering Co Vs. UOI-1995 (75) ELT 257 (Guj); (iii) Evergreen Engineering co. Pvt. Ltd. Vs. CCE-2012 (278) E.L.T. 328 (Tri. - Mumbai); 44. In the present case SISCOL cannot be considered as a jobbthe assessee who was taking credit nor was it used in their factory though there are some arguments OQ the second part of the statement. 45. Now it is time for answering the issues raised. If issue-I is seen independently, then tt may appear that precedent decisions support the 'case of the appellant. For this one has to ignore that those 'decisions were given in the context of a job-worker taking credit of duty suffered by the main manufacturer. In such decisions, credit was allowed to be taken by the job-worker, when the goods were owned by the main manufacturer, apparently for the reason that the capital goods were in the factory of the jobb the capital goods were in fact used in its factory ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of accounts of the owner is not audited normally as in this case wherein the owner of the goods is not a Central Excise assessee. The owner may even refuse permission for such audit and the information can be extracted only through a procedure 'of issue of summons. Further it can also lead to a situation where someone sets up a power plant supplies part of the electricity to a manufacturer who takes credit and sells the rest of the electricity to the public. The next step can be, for illustration, a factory of SAIL can take credit of duty paid on equipment used by NTPC in a power plant for the reason that the power from NTPC is used in the factory of SAIL at least partially. Such benefits are not intended by the scheme. So I dot agree with the proposal for further liberalization of the conditions laid down in the rules. 48. Now let me examine Issue-Ill. The land was leased out to JSWPL.JS\IVPL in turn pledged the land to take a loan from UTI Bank. In such situation can the land be considered as belonging to SISCOL?In the matter of deciding the ownership of a land weight of 9 out of 10 is given to possessionand only 1 out of 10 is given to legal title. In this case the legal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ere was no eligibility for the credit. However while deciding matters off penalty these future event can be taken into account. 50. Now there is a need to examine the main decision relied upon by the appellant which is the decision of the Apex Court in State of UP and Others Vs. Renusagar Power Company and others (AIR 1988 SC 1737). Here the facts were that M/s HINDALCOhad set up a, power plant through a 100B0/o subsidiary namely Renusaqar Power Co., a power plant which started producing power and supplying power to HINDALCO in 1967. Under the Electricity Duty Act, 1952 of the State of UP electricity duty was payable on electricity other than from own source of generation . UP State demanded such duty from Renusagar Power Co. because power was belnq supplied to another company, namely HINDALCO. The Court ruled that the demand is not maintainable because essentially .both Renusgar Power Co. and HINDALCO were the same. While giving the decision the Court observed as under: 64. It is high time to reiterate that in the expanding of horizon of modern jurisprudence, lifting of corporate veil is permissible. Its frontiers are unlimited. It must, .however, depend primarily ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat footing alone; this is evident in view of the principles enunciated and the doctrine now established by way of decision of this .Court in Life Insurance Corpn of India, (supra) that in the facts of this case sections 3(1)(c) and 4(1)(c) of the Act are to be interpreted accordingly. The person generating and consuming energy were the same and the corporate veil should be lifted. In the facts of this case Hindalco and Renusagar were inextricably linked up together. Renusagar had in reality no separate and independent existence apart from and independent of Hindalco. 68. In the aforesaid view of the matter we are of the opinion that consumption of energy by Hindalco is clearly consumption by Hindalco from its own source of generation. Therefore, the rates of duty applicable to own source of generation have to be applied to such consumption, that is to say. I paisa per unit for the first two generating sets and nil rate in respect of 3rd and 4th generating sets. It is appropriate to refer that having regard to the conduct of the State the power-cuts matter and also the present proceedings the State should not be permitted to treat consumption of Rehusagar's energy by Hindalc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t a benefit by lifting corporate veils of two companies because of the peculiar facts of the case .and also because the Governments themselves were considering the two companies to be one and the same in many matters. The issue to be decided was meaning of the expression own source of generation in which case there can be a doubt whether a subsidiary company's resources are the resources of a holding company. No such fact or law exists in this case. Indiscriminate lifting of corporate veil to grant benefits to the parties who claim themselves to be different can be disastrous. 54. The case of SAIL reported at 2007(219) ELT 960 (Tri-Del) also deals with a situation were the holding company took credit and then spun off a new company having the capital goods separated from the parent company. The facts are not comparable because this case deals with a situation of taking credit itself and the transactions are not between holding company and subsidiary company. It is also relevant that in the case of Majestic Auto Ltd-2004 (173) ELT 145 (Tri-Del) where one company took credit and then transferred the assets to another company with no relationship of holding company and subsid ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ar Das 57. The point of difference of opinion has already been set out above. 58. The facts of the case have also been narrated by the learned Judicial Member in his order. 59. The learned Advocate Shri Shivdass on behalf of the Appellant, supported the order of the learned Judicial Member and also made the submissions at length. He has filed a written synopsis with compilation of the case laws in support of his submission. On the other hand, the Ld. Authorized Representative, Shri M. Rammohan Rao on behalf of the Revenue, supported the order of the learned Technical Member and also drew the attention of the Bench, the relevant portion of Adjudication order and various provisions of law and made his submission elaborately. He has also submitted a written submission with case laws, which are kept on record. 60. After hearing both sides, and on perusal of the records, I find that it has been alleged in the show cause notice dated 19.9.2006 and 16.4.2007 that during the period from September 2005 to March 2006 and July 2006 to October 2006 respectively, M/s.SISCOL have wrongly taken and availed the cenvat credit on capital goods, which are not received by them, not in pos ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 06, the lease deed was terminated and by a tripartite agreement between M/s. SISCOL, M/s.JSW Steel Ltd. and UTI Bank Ltd., the Power Plant was transferred to M/s.SISCOL. Prior to 31.8.2006, M/s.SISCOL had not received the capital goods in their factory premises. Goods were not in possession of or ownership of M/s.SISCOL. There was no relation of principal manufacturer and job worker between SISCOL and JSWPL. The ground plan, which was existing prior to such leasing out cannot be sought to be relied upon by the assessee for their wrongful availment of Cenvat credit. 63.1. He has also drawn the attention of the Bench to various provisions of Cenvat Credit Rules as under:- (i) Rule 2 (a) (l) : - The Capital Goods should have been used in the factory of the manufacturer of the final products or for providing output service; (ii) Rule 3(1) : - A manufacturer or producer of final products shall be allowed to take credit of the duty paid on any inputs or Capital Goods received in the factory of manufacturer of final product; (iii) Rule 4(2):- The Capital Goods should have been received in the factory of the manufacturer and also should be in the possession of manufacturer of f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ve, the Renusagar Power Plant is a captive power plant of the Appellant 64.4. In view of the above decision, it is apparent that capital goods/input/input service used on power plant situated at a different premises CENVAT credit is admissible subject to exclusive supply of power by the impugned plant to the assessee manufacturing unit. In the present case, the capital goods were used to set up power plant for generation of electricity primarily for use in the manufacture of the final product within the factory of M/s.SISCOL. So, if the power plant is situated outside the factory premises, cenvat credit on capital goods used for setting up power plant cannot be denied as the electricity is captively consumed within the factory of M/s.SISCOL. 65. The main contention of the Ld. A.R is that the concerned power plant is not an integral part of the manufacturing unit namely M/s.SISCOL. It is contended that power plant was not acquired by M/s.SISCOL on loan, lease or hire purchase or loan agreement from a financing company as per Rule 3(5) of the said Rules. To sum up, there is no relation between M/s.SISCOL and M/s.JSWPL and it would lead to neighbour taking the credit on capital ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the present and future requirements of SISCOL. This communication clearly shows that JSW Power did not consider the land as that of theirs but that of SISCOL's. (iii) The Lease Agreement for the land is dated 17.01.2005. The Lease Agreement is between SISCOL and JSW Power Ltd., Clause C reads as SISCOL requested JSW Power Ltd., to set up a power plant of 60 MW at the SISCOL premises to take care of power requirements of SISCOL to which JSW Power agreed. Clause D reads as for the purpose of setting up the power plant, SISCOL agreed to lease a portion of demised land admeasuring about 50.14 acres. The term of the lease was 15 years from 01.01.2005. The actual rent is Rs.10,000/- only. This document also proves that the lease was for the setting up of a power plant for SISCOL only. (iv) The letter dated 26.04.2006 of SISCOL addressed to the Chief Engineer, Tamil Nadu Electricity Board, Chennai is for parallel operation and wheeling of power for 2 x 30 MW CPP. Here, SISCOL is asking the Electricity Board for approval for grid paralleling and wheeling of power for 2 x 30 MW power plant. The letter also says that the plant will be commissioned in the first week of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al Companies (Special Provision) Act, 1985 as evident from Summery Record of Proceedings of Hearing on 23.8.2005 of BIFR. (ii) There was a proposal dated 14.10.2004 for restructuring of debts of M/s.SISCOL under the CDR (Corporate Debt Restructuring) mechanism by CDR cell. It is seen from Terms and conditions of Restructuring Packages that completion date shall be 18 months from the date of effective take-over by the Sajjan Jindal Group (SJG). The borrower/SJG to take up with existing/new tenders to bridge the gap in the event of fund not being made available by IFCI and SIB. Instrument shall be finalized to the mutual satisfaction of SJG and lenders. The SJG shall arrange for merger of the SISCOL with its major group steel company. (iii) The Directorsb Unit III (Expansion) Jindal South West (JSW) Group has recently taken over Southern Iron Steel Company Limited (SISCOL) Pottaneri, near Salem. SISCOL's current capacity is 300,000 tons per annum and as per the CDR scheme approved by their lenders, SISCOL is doubling its capacity to 600,00 tons per annum SISCOL also proposes to set up a coke oven plant with capacity of 400,000 tons per annum. The power requirement of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in the Company's premises at Pottaneri, Mettur Taluk, Salem District with TNEB's Grid as per Sub-Section (2) of Section 9 and Clause (d) of Sub-Section (2) of Section 39 of the Electricity Act, 2003 68. Section 105 of the Transfer of the Property Act defines a lease of immovable property in the following words : A lease of immovable property is a transfer of a right to enjoy such property, made for a certain time, expressed or implied, or in perpetuity in consideration of a price paid or promised, or of money, a share of crops, service or any other thing of value, to be rendered periodically or on specific occasions to the transferor by the transferee, who accepts the transfer on such terms. Explaining this definition, Mulla had observed as follows in Transfer of Property Act: The essential elements of a lease are (1) the parties, (2) the subject-matter, or immovable property (3) the demise or partial transfer (4) the term, or period, and (5) the consideration, or rent. 68.1 On perusal of the lease agreement, it is seen that the Lessor (SISCOL) requested to the Lessee (JSWPL) to set up a power plant in the premises of the Lessor (SISCOL) to ta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r the cases where the ownership of the capital goods does not vest in the manufacturer until the loan is repaid. There must be an agreement for the purpose of acquiring the capital goods. The Tribunal in the case of Iljin Automotive India Ltd. Vs CCE Chennai . 4. Taking into account of overall facts and circumstances of the case and records, it is clearly evident that even prior to 31.8.2006, it was a Captive Power Plant of M/s.SISCOL as approved by TNEB under the Electricity Act. SISCOL was a sick unit. They entered into lease agreement with M/s.JSWPL, a relationship had already been developed prior to October 2005, as evident from CDR Cell report, JSWPL balance sheet etc., for financial accommodation to get loan from UTI Bank Ltd. for setting up C.P.P. and one of the considerations is that electricity would be supplied to M/s.SISCOL, which is an integral part of manufacturing activities of M/s.SISCOL. 69. In view of the above discussion, I find that it is proper to allow cenvat credit to M/s.SISCOL from October 2005 on capital goods used in setting up Power Plant for generation of electricity, which was captively consumed within the factory of M/s.SISCOL for manufacturing o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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