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Case of Nirma Ltd on valuation of Excisable goods- a study of recent judgment of the Supreme Court and related judgment of Tribunal passed ten year ago.

Case of Nirma Ltd on valuation of Excisable goods- a study of recent judgment of the Supreme Court and related judgment of Tribunal passed ten year ago. - Central Excise - By: - CA DEV KUMAR KOTHARI - Dated:- 19-11-2015 - Judgments under direct study in this article: C.C.E., Vadodara-I Versus M/s. Nirma Ltd. & Ors. 2015 (11) TMI 605 - SUPREME COURT Civil Appeal No(s). 3621/2007 Dated - 09 October 2015 read with: NIRMA LTD. Versus COMMISSIONER OF CENTRAL EXCISE, VADODARA-I 2005 (8) TMI 337 - .....

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0-1996 Rule 173C The Cost Audit (Report) Rules, 1996 issued under Section 233 of the Companies Act, 1956 Accounting Standard-2 (AS-2, for short) issued by The Institute of Chartered Accountants of India. Judgmetns considered: M/s. Calcutta Chromotype Ltd. v. CC, Calcutta - 1998 (3) TMI 138 - SUPREME COURT OF INDIA K.T. Doctor v. CIT - 1980 (1) TMI 64 - GUJARAT High Court, the Gujarat High Court has already held that doctrine of lifting of corporate veil cannot apply to trust. National Aluminium .....

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on of cost of production is to be made as per Cost Accounting Standard 4 . The Tribunal has kept in mind the Costing Accounting Standard - 4 (CAS-4) which has been adopted by the Department itself.[per author- departmental instructions / circular exists in this regard which are binding on authorities.] On that basis, it has come to the conclusion that the three elements of cost namely interest expenditure, depreciation and profit margin which were sought to be included by the Department could no .....

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hor feels that in give case considerable costs should be imposed on Revenue for filing un-necessary appeal. In this case the revenue has intended to impose penalties not only on manufacturer but also on its Managing Director and General Managers of Factories. When penalties on executives can be intended and / or imposed then there should also be provision to impose penalty on erring officers of revenue who issues un-necessary show cause notices, orders demand, and also indulge in un-necessary li .....

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Kumar, Adv., Mrs. Aruna Gupta, Adv., Mr. Jitin Singhal, Adv., Mr. Pratik, Adv. And Mr. B. Krishna Prasad,Adv. For the Respondent : Mr. V. Sridharan, Sr. Adv., Mr. M. P. Devanath,Adv., Ms. L. Charanaya, Adv., Mr. Hemant Bajaj, Adv., Mr. T.D. Satish, Adv., Mr. Anandh K., Adv. And Mr. Aditya Bhattacharya, Adv. ORDER The issue involved in the present appeal relates to the alleged under valuation of Linear Alkyl Benzene (LAB) which is manufactured and cleared by the respondent - assessee herein to it .....

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he parties are ad idem that the costing of LAB is to be done as per Rule 8 of the Valuation Rules, 2000 which prescribes cost method. The appellant-Department had issued five show-cause notices to the respondent herein for different periods alleging therein that the costing as done by the respondent - assessee was not in accordance with the method of costing and it resulted in under valuation and thus lesser payment of duty. The differential duty was, thus, demanded. The respondent herein, on go .....

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3.18 365.34 365.34 (-) Catalyst cost not includible 190.50 1190.50 1190.50 (=) Interest Expenditure 0.00 623.38 623.38 (9)=(4)=(5)-(6)-(7)+(8) 35522.15 34057.96 34057.96 (+) Profit Margin @ 10% (10) 3552.22 34005.80 34005.80 Cost of production as per submissions (11) = (9) + (10) 37764.81 36154.20 36154.20 Value at which duty has been paid (12) 37700.00 37700.00 45000.00 (upto December) (1999) 46500 (From January 2000) The demand was confirmed after considering the reply that was filed by the re .....

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s barred by limitation in respect of other four show-cause notices after arriving at the findings, as mentioned above. In respect of first show-cause notice which applies to these notices as well, there is a demand on the limited aspect for calculation of the cost. Mr. K. Radhakrishnan, learned senior counsel appearing for the Department made various submissions questioning the correctness of the view taken by the Tribunal. He further argued that once there was a demand in respect of four show-c .....

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onsideration for arriving at the cost of production. After going through the reasons given by the Tribunal in support of the aforesaid conclusions, we find no error therein. The appeal is accordingly dismissed. In view of the above, the appeals are dismissed. 2005 (8) TMI 337 - CESTAT, MUMBAI Other Citation: 2006 (200) E.L.T. 213 (Tri. - Mumbai) NIRMA LTD. Versus COMMISSIONER OF CENTRAL EXCISE, VADODARA-I E/389-392/2004 Order No. - A/1650-1653/2005-WZB/C-III Dated - 26 August 2005 Valuation (Cen .....

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mand (Rs.) 1 25-2-2000 December 1997 to January 2000 23,25.59,177 2 17-1-2001 February 2000 to August 2000 5,21.35,821 3 11-9-2001 September 2000 to October 2000 85,15,995 4 7-12-2001 November 2000 to March 2001 2,55,66,530 5 3-5-2002 April 2001 to November 2001 5,88,39,727 TOTAL 37,76,17,250 1.2 During the period covered by first show cause notice i.e., December, 1997 to January, 2000, about 61% of the LAB production was stock transferred from Alindra plant to other plants located at Trika .....

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hort, C&SI). Balance 6.5% of the production was exported is the portion submitted by the appellant. 1.3 LAB manufactured at Alindra was transferred to other factories on payment of duty on the price at which LAB was being sold to KI & others. Accordingly the assessable value of LAB per MT on which excise duty was paid by the appellants during the period December, 1997 to January, 2000 was as : Period Rs. December 1997 to March 1999 37,700 April 1999 to December 1999 45,000 January 2 .....

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plant, cost of the raw materials, depreciation, overheads, selling and marketing expenses, sales tax/income tax exemption etc. pertaining to RIL. IPCL and TNPL are different when compared with the appellants Alindra plant. It is difficult to make adjustments for these factors. Therefore assessable value cannot be calculated under Rule 6(b)(i). Hence, Rule 6(b)(ii) alone would be applicable. (c) Correct catalyst cost, interest and profit margin have to be added to the cost of production already .....

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values as : for the Period Rs. December, 1997 to March, 1998 51,755 April, 1998 to January, 2000 51,799 1.5 The other four notices are as : Period Valuation based on which LAB was stock transferred to other factories Basis of demand by the notices February 2000 to August 2000 Pre July 2000 : Price at which LAB was being sold to KI. Post July 2000 : 115% of cost of production in terms of Rule 8 of Valuation Rules, 2000 reproduced below : Where the excisable goods are not sold by the assessee but .....

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lue equal to ₹ 48,000 per MT being the last sale price of LAB to KI. 115% of Cost of production as submitted by the appellants except for the interest element. This show cause notice adopted the interest element from the show cause notice dated 25-2-2000. November 2000 to March 2001 The appellants discharged duty on LAB on assessable value equal to ₹ 48,000 per MT being the last sale price of LAB to KI. Rule 8 of the Valuation Rules, 2000 is not applicable for captive consumption and .....

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ion Rules, 2000. Since the appellants had sold LAB at die maximum assessable value of ₹ 54,350 per MT, this value should be the assessable value for LAB captively consumed. 1.6 All these notices were broadly contested on : (a) Reasons given in show cause notice to treat KI (i.e., KDFT) as not an independent buyer were incorrect. (b) KDFT is an independent entity having its own investments in plant & machinery, workers, finance arrangements, know-how etc. Therefore, KI (i.e. KDFT) is an .....

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r reasons given in the show cause notice do not influence the price of comparable goods, namely, LAB manufactured by RIL/IPCL/TNPL. Hence, Rule 6(b)(i) is very much applicable. (f) If reasons given in the show cause notice to ignore the price of the comparable goods are accepted, then Rule 6(b)(i) would be rendered redundant and otiose. (g) If the price of comparable goods under Rule 6(b)(i) is taken as the basis and adjustment for difference in quantity level is given, no demand survives. (h) C .....

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ncluded in the cost of production of LAB by the show cause notice is exaggerated and excessive and in fact exceeds total interest of the company as a whole itself. (iv) Total interest expenditure of the company as per audited profit and loss account as a whole should be reduced by interest income as per said audited profit and loss account. Net interest expenditure alone should be allocated on gross block basis, a method suggested in the show cause notice itself. (v) Interest, per se, is not inc .....

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otice, then no demand practically survives. (i) Since, much more duty has already been paid through PLA by the recipient factories, no demand can lie under Section 11A. (j) Since Modvat credit is available to the appellants own factories, proviso to Section 11A is inapplicable and hence entire demand is time-barred. (k) Reference to seized documents indicating higher cost of production is irrelevant since even show cause notice has not computed cost of production on the basis of these seized doc .....

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family & they supplying the packaging material being manufactured by them and finding that LAB sales make to subsidiaries benefited the appellants as they could purchase detergent back from them, rejected the pleas made & concluded the under-valuation. Confirmed the demands as made in the main notice. 1.7.2. Thereafter for the four other notices it was found that application of the Board costing formula communicated vide Order No. 692/8/2003-C.X., dt. 13-2-2003 would be called for, .....

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nterest and (c) profit margin. (i) The notice dated 25-2-2000 calculates the cost of production of LAB by relying on the cost of production given by the appellants to the investigators i.e. DGAE. The show cause notice accepts all other elements of cost and disputes only following three elements of costs while calculating the cost of production of LAB : (a) Catalyst; (b) Interest; and (c) Profit margin As regards Catalyst : It is on record that the appellants had imported catalysts under the EPCG .....

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yst while calculating the cost of production of LAB. (i) The first charge of a catalyst is in the form of permanent investment and to be treated as fixed asset. Since first charge of catalyst is in the nature of fixed asset, the appellants charge depreciation on it, at the rates prescribed under Companies Act, 1956. This accounting policy cannot be found fault with as it is in line with generally accepted accounting principles. The statutory auditors have also not objected for such an accounting .....

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t. (c) The actual foreign exchange ratio and actual consumption should be taken into consideration. These submissions at (a), (b) and (c) above are further explained as depreciation provided on such catalyst have been included by the appellants in the total depreciation calculated for the plant as a whole. In the calculation done by the department, the total depreciation has been included in the cost of production of LAB. The show cause notice, therefore, would duplicate the cost of catalyst by .....

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164.15 12,815 402.67 1998-1999 3,21,81,139.00 58,931 546.08 1999-2000 546.08 (ii) The department has issued another show cause notice No. DGCEI/WZU/205/30-149/01, dated 29-10-2001, where it has been alleged that the appellants have sold the precious metal recovered from the spent catalyst. This show cause notice has been adjudicated and appeal filed against the Order-in-Original has been allowed by this Tribunal. The realization of ₹ 500.14 lacs from the sale of precious metal recovered fr .....

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sequent to the period covered by the present show cause notice. Hence, the above realisation figures would be entirely against the catalyst which have been used for the period in the question. The appellants submit that while computing the cost of catalyst one has to reduce the amount realized from the sale of precious metal recovered from spent catalyst and thereafter such reduced/net cost of catalyst only should be amortized over the life of the catalyst and included in the cost of production .....

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realized by sale of precious metal recovered from spent catalyst (Rs./MT) (1) (2) (3) (4)=(2)*(3) 1997-1998 1948 17.10% 333.18 1998-1999 2136 17.10% 365.34 1999-2000 365.34 (iii) We would agree with these submissions as they are supported by CAS-4, whose relevant paras reproduced below : 4.1 Cost of Production : Cost of production shall consist of Material Consumed, Direct Wages and Salaries, Direct Expenses, Works Overheads, Quality Control cost. Research and Development Cost, Packing cos .....

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uction by Credit for Recoveries/Scrap/By-Products/ Misc income . The appellants also relied upon solutions to costing problems provided in a book by Mr. Bhar to support the above view. We find nothing contrary to rebut the same. (iv) The show cause notice has relied upon cost sheets referred to in the statements of Mr. Gunasekhar and Mr. Joshipura, for arriving at the catalyst cost. It is submitted that both the cost sheets were made on ad hoc basis and were based on provisional figures. These s .....

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180 43885090.71 4780.51 Total 17400 84189348.13 4838.47 Detal Catalyst Qty. in Kgs. CIF as per B/E Rate per Kg (Rs.) 1 2 3 4=(3/2) 1 DA-11 97278.9 (214500 lbs converted in Kgs) 204985727.99 2107.20 Further, these sheets also assumed consumption ratio of 0.13 Kg of Pacol catalyst and 0.2590 Kg of Detal catalyst for manufacturing 1 MT of LAB. However, actual figures now available show that the consumption ratio considered in the cost sheet is on the higher side. The actual consumption ratio is 0.0 .....

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in para on following grounds : (i) Shri Joshipura and Shri Kalpesh Patel are responsible persons of the appellants and therefore the department had no reason to believe that the cost supplied by them are not correct. (ii) Any manufacturer would definitely know the cost so that he can determine the selling price of their product. We find no reason to uphold these findings in the impugned order. Shri Joshipura and Shri Kalpesh Patel are no doubt responsible employees of the appellants-company, but .....

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concept of cost. Costs are prepared under various basis at various points of time for various purposes. Valuation under Central Excise law is concerned with actual costs and not estimated costs. The employees of the appellant had submitted costs of catalyst, which was estimated by them at an earlier point of time based on certain assumptions. Such estimated cost will not be available for calculating cost of production under Rule 6(b)(ii). Hence the correct cost of catalyst which has been ignore .....

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avour of head office as ₹ 340.27 crores on 31-1-1998, ₹ 381.05 crores on 31-3-1998 and ₹ 382.42 crores on 31-3-1999. Thus, on 31-1-1998, in the books of LAB division, Head Office was shown as a creditor for ₹ 340.27 crores being total capital cost of the LAB plant. As per statutory accounting principles, interest incurred up to the date of commencement of commercial production forms part of the capital cost of the LAB project. Accordingly, credit balance was calculated on .....

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res was deducted from total interest of the year 1997-98 of ₹ 42.62 crores for the company as a whole. In the books of LAB division, credit balance in favour of Head Office was shown as ₹ 340.27 crores as on 31-1-98. Therefore, out of ₹ 381.05 crores and ₹ 382.42 crores shown as payable by LAB division to other divisions as on 31-3-1998 and 31-3-1999 respectively, ₹ 366.67 crores is towards for the capital cost of LAB plant. (ii) The method adopted by the show cause .....

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ted for the period December, 1997 to March, 1998 and year 1999-2000. (iii) Interest per se is not includible in the cost of production, as per CAS-4 as interest expenditure is purely a finance cost. It has got nothing to do with manufacture of goods. Therefore, it is not includible in the cost of production. This principle is shown to be recognised by the Central Government. The Cost Audit (Report) Rules, 1996 issued under Section 233 of the Companies Act, 1956 require the cost audit information .....

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ants of India has issued Accounting Standard-2 (AS-2, for short) for the purpose of valuation of inventory. The AS-2 is mandatory in nature and it is to be compulsorily followed by those governed by it. This is in turn based on International Accounting Standards prescribed by an International Body. Paras 5, 6 and 12 of AS-2 is extracted below : MEASUREMENT OF INVENTORIES 5. Inventories should be valued at the lower of cost and net realisable value. COST OF INVENTORIES 6. The cost of inventories .....

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CAS-4. for short) issued by ICWAI relating to valuation of goods captively consumed. Para 3 of the circular dated 13-2-2003 clarifies that cost of production of goods captively consumed will henceforth be done strictly in accordance with CAS-4. Relevant para of CAS-4 is extracted below : 5.16 Interest and financial charges Interest and financial charges being a financial charge shall not be considered to be a part of cost of production These Circular dated 13-2-2003 clarified that cost of produc .....

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ted 13-2-2003 is not applicable for past period is incorrect and liable to be rejected. The Tribunal in ITC Ltd. v. CCE - 2004 (175) E.L.T. 860 (T) has held that interest per se is not includible in the cost of production. Therefore we find no ground to uphold the interest costs. (c) Amount of interest calculated in the show cause notice for LAB division alone far exceeds the total interest incurred for the company as a whole. This shows that interest as calculated by show cause notice is ex fac .....

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8-99 enclosed as Annexure-41 to the appeal memo). This absurdity has resulted because the entire method adopted in the show cause notice for calculating interest is incorrect & therefore cannot be upheld. Since the cost and interest taken for the year 1999-2000 (up to January, 2000) in the show cause notice is the same as that of year 1998-99, the submission made above equally applies for the year 1999-2000 also. The above position equally applies for the period December, 1997 to March, 1998 .....

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rely a notional figure - under Section 4, no such notional addition is possible. It is to be found that the inter-divisional balance is in the nature of contra entries. When these inter-divisional balances are merged, the contra entries cancel each other. In other words, amount owed by LAB division to other divisions of the company does not mean that the amount is owed by the Company as a whole. The finance needed for setting up LAB plant was given by Head Office. This can be and is out of past .....

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.T. 483 (S.C.) (c) Union Carbide v. CCE - 2003 (158) E.L.T. 15 (S.C.). It is found that submissions made with respect to interest have not at all been considered by the impugned Order-in-Original. Hence the order is liable to be set aside in its entirety. (f) On Profit the show cause notice dated 25-2-2000 has calculated profit margin of 19.8% for the year 1997-98 and 17.95% for the year 1998-99 and 1999-2000 based on figures pertaining for the company as a whole taken for additional profit and .....

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modity. It is bought and sold in bulk. Its chemical composition is well defined and its standards are fixed. Whereas, on the other hand, detergent powder and cakes are branded products sold in retail to the ultimate consumer. Therefore, adopting profit margin of branded consumer product like detergents as the profit margin of an industrial chemical like LAB is illogical. (ii) It is found that the Larger Bench of Tribunal in Raymonds Ltd. v. CCE - 2001 (129) E.L.T. 327 (T-LB) held that profit or .....

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of profit margin of 10% is reasonable in the circumstances. In fact, the burden is on the department to first establish that LAB division is a profit making operation/unit. Without establishing this, no profit margin at all can be added by the department. (iii) Submissions made by the appellant, with respect to profit margin have not at all been considered by the impugned Order-in-Original. In view of the above it is liable to be set aside in its entirety. 2.1.2 It is submitted that revised cost .....

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0 (+) Interest expenditure (8) 0.00 623.38 623.38 (9) = (4)-(5)-(6)-(7)+ (8) 35522.15 34057.96 34057.96 (+) Profit Margin @ 10% (10) 3552.22 3405.80 3405.80 Cost of production as per submissions (11) = (9) + (10) 37764.81 36154.20 36154.20 Value at which duty has been paid (12) 37700.00 37700.00 45000.00 (up to December 1999) 46500.00 (From January 2000) Which would shows that the revised cost of production for the year 1997-98 is merely 0.17% higher than the value at which LAB was transferred b .....

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on of relevant submissions made in defence by the noticee. 2.2.1. As the LAB recipient factories had paid much more duty in PLA than now being demanded by the show cause notice dated 25-2-2000. In such situations, there cannot be any intention to evade payment of duty, more so when it is considered to be a related person or same person sales by Revenue. Ingredients of proviso to Section 11A therefore can not be attracted. Hence demand beyond one year period of limitation is barred. 2.2.2. The co .....

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cost sheet would have made it abundantly clear that interest expenditure, depreciation and profit margin were not included. The Range obviously noted the same but found nothing incorrect in it. If DGAE has different understanding of cost of production, that cannot be a ground for invoking proviso to Section 11A against the appellants. 2.2.3. The appellants had also filed price declaration in terms of Rule 173C wherein it was stated that sale price to Kissan Industries is being adopted as th .....

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ed for each removal. Rule 8 of these Valuation Rules, 2000, is reproduced below : Where the excisable goods are not sold by the assessee but are used for consumption by him or on his behalf in the production or manufacture of other articles, the value shall be one hundred and fifteen percent of the cost of production or manufacture of such goods. As per CBEC Circular dated 1-7-2002, goods cleared to sister unit or other unit of the same company, valuation has to be done as per proviso to Rule 9 .....

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ds are not sold to buyers, to buyers (being related person), who sells such goods in retail : Provided that in a case where the related person does not sell the goods, but uses or consumes such goods in the production or manufacture of articles, the value shall be determined in the manner specified in Rule 8. In view of the above, LAB cleared to other factories of the appellants should be valued as provided under Rule 8 i.e., 115% of the cost of production of LAB. The appellants had repeatedly s .....

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vember, 2000 to November, 2001 has been confirmed under Rule 4 read with Rule 11 of the Valuation Rules, 2000. It is submitted that even of the case of the department is assumed to be correct that KI is related person, still clearances of LAB to KI and other factories of the appellants is to be governed by Rule 8 and Rule 9 of the Valuation Rules, 2000. Rule 8 and Rule 9 are more specific provisions relating to valuation of LAB captively consumed, then Rule 4 read with Rule 11. It is settled law .....

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