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2016 (5) TMI 597 - MADRAS HIGH COURT

2016 (5) TMI 597 - MADRAS HIGH COURT - 2016 (341) E.L.T. 522 (Mad.) , [2016] 92 VST 257 (Mad) - Valuation - Whether the Anti-Dumping Duty levied on the imported components and paid by a company which purchased the finished products from the petitioner herein would form part of the sale price of the goods manufactured and sold by the petitioner to such buyer under the provisions of TNVAT Act, 2006 - Petitioner located in a Special Economic Zone, enjoying exemption under Section 26 of the SEZ Act, .....

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Zone. This exemption was available just like a shelter so long as the goods were in the Special Economic Zone. The moment the goods got removed from out of the shelter into a Domestic Tariff Area, Section 15 of the Tamil Nadu Special Economic Zones Act and Section 30 of the Central enactment came into play. As a consequence, the anti dumping duty became payable. - The purchaser paid the same or the fact that the sale had taken place prior to the clearance of the goods, is of no consequence, .....

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is of significance. - Therefore, the anti dumping duty actually became leviable from the time of export from China into India, but was not actually collected due to the protective cover given by the Special Economic Zones Act. The moment the goods went out of this protective cover, the duty automatically got attached to the goods and hence, the inclusion of the same in the sale price for the purpose of levy of value added tax is in order. Once anti dumping duty is levied, the same becomes p .....

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re (i) the assessing authority should be satisfied, (ii) that the escape from the assessment was due to wilful non disclosure of assessable turnover by the dealer. Sub-section (4) of Section 27 also deals with penalty, in relation to the reversal of input tax credit under Section 27(2). The penalty under Sub-section (4) is on a graded scale, with the rate of penalty for second and subsequent detections, higher than the rate in the case of first detection. - No finding of fact was recorded b .....

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one paragraph, the Appellate Authority held that there was a wilful intention on the part of the assessee to evade the taxes by adopting a device and by filing incorrect and incomplete returns. In other words, the Appellate Authority did not also address himself to the question as to whether there was wilful non disclosure or not. Unfortunately, the Tribunal also misdirected itself on this issue. Therefore, the imposition of penalty at the rate of 150% under Section 27(3)(c) of the TNVAT Act, 20 .....

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ods. This first clearance was made by the petitioner, when they imported the components from Huawei Technologies Co. Ltd., China. This clearance was allowed to be made without payment of duty because of the location of the petitioner in a Special Economic Zone. Therefore, the petitioner is not entitled for refund of tax inadvertently paid on CVD component. - Decided partly in favour of petitioner - Tax Case Revision No. 35 of 2014 - Dated:- 18-4-2016 - V. Ramasubramanian And T. Mathivanan, JJ. F .....

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that the Anti-Dumping Duty on the imported components paid by the buyer (customer of the petitioner) formed part of the "sale price" of the goods manufactured and sold by the petitioner to the buyer under the provisions of the Tamil Nadu Value Added Tax Act, 2006? (ii) Whether on the facts and in the circumstances of the case, the learned Appellate Tribunal was correct in law in holding that tax and penalty are imposable upon the petitioner under the provisions of the Tamil Nadu Value .....

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leader (Taxes) appearing for the State of Tamil Nadu. 3. The petitioner herein is a company which is authorised to carry on certain operations in their unit located within the Special Economic Zone at the SIPCOT Industrial Park, Sriperumbudur, Kancheepuram District. In the course of the authorised operations, the petitioner manufactured and sold Optix OSN Series Intelligent Optical Transmission Platforms, referred to as "Optical Cabinets", to a company by name Huawei Telecommunications .....

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porting the components without payment of basic Customs Duty and CVD, the petitioner manufactured Optical Components and sold them to Huawei India. The sale was subject to payment of appropriate VAT under the TNVAT Act, 2006 and Central Sales Tax Act under the CST Act, 1956. 6. The sale and supply of goods between the petitioner and Huawei India were on an "ex-works basis" in terms of a Supply Agreement dated 31.3.2010. Under Clause 3.2.2 of the Supply Agreement, the petitioner is obli .....

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5/2010-Customs, imposing Anti-Dumping Duty at the rate of 266% on the import of certain transmission equipments and sub-assemblies and components, when imported from China. The said notification was given retrospective effect from 8.12.2009, on account of the fact that a provisional levy had already been made earlier. 8. However, as the unit of the petitioner was located in the Special Economic Zone, the imported goods were not subjected to Anti-Dumping Duty at the hands of the petitioner. Howev .....

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value of imported components. According to the petitioner, this payment was made by the purchaser, without any notice or intimation to the petitioner. 10. Subsequently, the Assistant Commissioner (Commercial Taxes) informed the petitioner by a letter dated 29.4.2011 that the value of Anti-Dumping Duty is to be included in the sale price, for the purpose of levy of CST under the CST Act, 1956. By another letter of the same date, the Assistant Commissioner (Commercial Tax) also issued a show caus .....

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al to revise the assessment by including the value of Anti-Dumping Duty paid by the purchaser, for the purpose of revising the tax liability. 13. Though the petitioner submitted a letter of objection dated 30.8.2011, and also participated in the personal hearing granted on 19.9.2011, the Assessing Officer passed a revised order dated 21.10.2011 demanding tax on a price that included Anti-Dumping Duty. This revision was made on best of judgment basis. A penalty at 150% was also imposed under the .....

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n of law is as to whether the Anti-Dumping Duty levied on the imported components and paid by a company which purchased the finished products from the petitioner herein would form part of the sale price of the goods manufactured and sold by the petitioner to such buyer under the provisions of TNVAT Act, 2006. The second question relates to the validity of penalty levied upon the petitioner. The third question relates to the tax paid by the petitioner on the CVD component, and the question of its .....

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EZ Act, 2005 and (b) that the goods manufactured and sold by the petitioner were cleared by the buyer by filing a Bill of Entry, indicating thereby that such a buyer is the importer and that as a consequence, he paid the Anti-Dumping Duty. 17. It is needless to point out that under Section 9A of the Customs Tariff Act, 1975, the Central Government is empowered to impose an Anti-Dumping Duty, whenever an article is exported by an exporter or producer from any country or territory, to India at les .....

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Official Gazette, impose an anti-dumping duty not exceeding the margin of dumping in relation to such article." 18. What is significant to note is that any export from any country or any territory into India is covered by this sub-section. Therefore, a Special Economic Zone which is considered to be a foreign territory located within the Indian territorial limits, is also included in sub-section(1) of Section 9A. Sub-section (1) also uses the expression "upon importation of such artic .....

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ty. The word "import" is defined in Section 2(23) to mean the act of bringing into India from a place out side India. The word "importer" is defined in Section 2(26), to include any owner or any person holding himself out to be the importer, if such word is used in relation to goods between their importation and the time when they are cleared for home consumption. 20. Under Section 45(1) of the Customs Act, 1962, all imported goods unloaded in a customs area shall remain in t .....

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ustoms port customs airport or land customs station. 21. Therefore, it is the contention of Mr.C.Natarajan, learned senior counsel for the petitioner (i) that the company which purchased the manufactured finished goods from the petitioner is identified as the importer (ii) that the act of importation of those goods into India happened after the sale of the goods by the petitioner to such person and (iii) that therefore, it was such purchaser who paid the Anti-Dumping Duty under Section 9A of the .....

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roduct from a country, on which anti dumping duty is normally liable to be paid, converts the product into another before it is cleared from the Special Economic Zone, no anti dumping duty is attracted. But, we do not know how this decision is applicable to the case on hand. In this case, the person who cleared the goods from the appellant's Unit in Special Economic Zone, has paid the anti dumping duty. Therefore, today there is no dispute about the liability to pay anti dumping duty. Hence, .....

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purpose of determination of the turnover, (ii) decisions which arose out of the inclusion of customs duty in the sale price, (iii) decision dealing with the time of happening of the taxable event, and (iv) Decisions dealing with the inclusion of other charges in the sale price. Decisions dealing with inclusion of excise duty in the sale price 24. In McDowell & Co. Ltd. v. Commercial Tax Officer [(1985) 59 STC 277 (SC)], a Constitution Bench of the Supreme Court was dealing with a second roun .....

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ry that a person cannot remove spirit or liquor manufactured or stored, unless excise duty had been paid by the holder of D2 license. On the basis of the amended provisions, the sales tax authorities again sought to include the excise duty paid directly by the buyers, in the manufacturer's turnover. The challenge made by the manufacturer was rejected by the High Court and when the matter was taken to the Supreme Court, the correctness of the decision rendered earlier by the two member Bench .....

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otal amount and not what was merely reflected in the bill. Therefore, the Court held that though the excise duty was paid by the buyer, it was part of the consideration for the sale and hence, includible in the turnover of the manufacturer. 25. In Mohan Breweries and Distilleries v. Commercial Tax Officer [(1997) 107 STC 212 (SC)], a three Member Bench of the Supreme Court was concerned with a question whether the excise duty on potable liquor, manufactured by Mohan Breweries, but paid by the pu .....

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ral Sales Tax Act, 1959, the Court held that excise duty formed part of the turnover and that the fact that it did not physically enter the manufacturer's till, was not the decisive test for determining whether or not it would be part of the manufacturer's turnover. 26. In State of Kerala v. Madras Rubber Factory [(1998) 108 STC 583 (SC)], the Supreme Court was concerned with a question whether the cess payable under the provisions of the Rubber Act, 1947, will form part of the purchase .....

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e Supreme Court on the ground that the liability to pay cess got attached to the rubber when manufactured and that when it is ultimately paid by the end user, namely the manufacturer, it is implicit that the element of cess payable would be one of the factors in determining the price payable in respect thereof. 27. Mr.C.Natarajan, learned senior counsel appearing for the petitioner sought to draw a distinction between all the aforesaid three decisions of the Supreme Court (McDowell, Mohan Brewer .....

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ies and taxes, stand on a different footing than the case of the assessees involved in the above three cases before the Supreme Court. 28. In order to test the correctness of the above contention, it is necessary to take a look at Sections 26 and 30 of the Special Economic Zones Act, 2005, which is a Central enactment and Sections 12 and 15 of the Tamil Nadu Special Economic Zones Act, 2005. Section 26(1) of the Central enactment and Section 12(1) of the State enactment grants exemption to every .....

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ction 15 of the State enactment Domestic clearance by Units. Subject to the conditions specified in the rules made by the Central Government in this behalf: (a) any goods removed from a Special Economic Zone to the Domestic Tariff Area shall be chargeable to duties of customs including anti-dumping, countervailing and safeguard duties under the Customs Tariff Act, 1975, where applicable, as leviable on such goods when imported; and (b) the rate of duty and tariff valuation, if any, applicable to .....

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9 and Tamil Nadu Additional Sales Tax Act, 1970 and the entry tax under the Tamil Nadu Entry of Motor Vehicles into Local Areas Act, 1990 and the Tamil Nadu Entry of Goods into Local Areas Act, 2001 where applicable, as leviable on such goods when imported; and (b) the rate of sales tax, additional sales tax and entry tax, if any, applicable to goods removed from a Special Economic Zone shall be at the rate in force as on the date of such removal, and where such date is not ascertainable, on the .....

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ore, it is clear that the chargeability to duty of customs, including anti dumping, countervailing and safeguard duties, arises upon removal from the Special Economic Zone to the Domestic Tariff Area and hence, the reasoning given by the Supreme Court in Madras Rubber Factory that the liability to pay cess got attached to the rubber, would apply equally to the case on hand. 32. As a matter of fact, the liability to pay anti dumping duty arises due to the import. The revision petitioner herein is .....

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re, the primary liability for payment of anti dumping duty actually falls upon the appellant, the moment the goods are removed from the Special Economic Zone to the Domestic Tariff Area. The Supply Agreement that the appellant had with their purchaser, in whatever clever manner they are worded, merely shifted the burden of payment of anti dumping duty to the buyer. To put it differently, the statutory liability for payment of anti dumping duty fell upon the petitioner by virtue of the statutory .....

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e in State of Rajasthan v. Rajasthan Chemists Association [(2006) 6 SCC 773 (SC)]. In that case, the Supreme Court was concerned with the validity of Section 4-A of the Rajasthan Sales Tax Act, 1994, by which sales tax was leviable not on the actual price, but on the MRP of the goods declared on the package. While upholding the judgment of the Rajasthan High Court declaring Section 4-A to be unconstitutional, the Supreme Court held that a tax cannot be levied on a person unconnected with the eve .....

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f Maharashtra [(1990) 77 STC 110 (Bom.)], the question that arose before a Bench of the Bombay High Court was whether the customs duty paid by the dealer's customer formed part of the sale price of the imported goods for the purpose of the Bombay Sales Tax Act, 1959 and Central Sales Tax Act, 1956. On the facts of the case, the Bombay High Court found that the contract of sale therein was a CIF contract and that the customs duty was paid by the buyer after completion of the sale. In other wo .....

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n of the expression "turnover", which was considered by the Supreme Court in Mohan Breweries, the decision of the Bombay High Court in Gujarat Export Corporation would have no application to the case on hand. Moreover, the distinction between statutory liability, which is merely passed on to someone as a contractual liability, was not noted by the Bombay High Court in the said decision. Therefore, we do not think that Gujarat Export Corporation can go to the rescue of the petitioner. D .....

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the customs station. Taking note of Section 5(2) of the Central Sales Tax Act, 1956, this Court held that for a sale to be one in the course of import, it has to be either one which has occasioned the import or has been effected by a transfer of document of title before the goods have crossed the customs frontiers of India. After referring to the definition of the expressions "customs station", "crossing the customs frontiers of India" and "customs port" under the C .....

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pon the goods crossing the customs barrier and not the date on which the goods had landed in India or had entered the territorial waters. But, in the case on hand, the dutiable event had actually taken place at the time when the goods were imported into India. But, the payment of the duty was exempt by virtue of the provisions of the Special Economic Zones Act. This exemption got withdrawn at the time of removal of the goods to the Domestic Tariff Area. Therefore, neither Kiran Spinning Mills no .....

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rom the warehouse. But, this decision is also of no assistance to the petitioner for the very same reason as to why Kiran Spinning Mills and State Trading Corporation cannot be invoked to the benefit of the petitioner. Decisions dealing with the inclusion of other charges in the sale price 39. In Srinivasa Timber Depot v. Deputy Commercial Tax Officer [(1969) 23 STC 158 (Mad.)], a Bench of this Court held that lot coolie charges paid on a percentage basis by the customers to the different assess .....

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as held by this Court to relate only to something done by the dealer in respect of the goods at the time of or before its delivery, which involves transfer of property. 40. Similarly, in Cauvery Sugars and Chemicals Ltd. v. Commercial Tax Officer [(1972) 29 STC 1 (Mad.)], this Court held that the cess paid on sugarcane brought into a local area specified in a notification cannot be treated as part of the turnover. But, to come to such a conclusion, the Court found on facts that as per the Madras .....

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Indian Made Foreign Spirits (Supply by Wholesale) Rules, 1981, formed part of the sale price or not. This Court answered the question in favour of the assessee on the ground that vend fee had nothing to do with the manufacturer, but was collected for the grant of a privilege or license to sell Indian Made Foreign Spirit. 42. In Commissioner of Trade Tax, Uttaranchal v. Poltawaski TPS Power Services [(2009) 23 VST 410], the Uttaranchal High Court was concerned with the question whether the custo .....

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ons in Srinivasa Timber, Cauvery Sugars, Thiru Arooran Sugars, Mohan Breweries and Commissioner of Trade Tax, Uttaranchal. These cases are not comparable to the case on hand. They deal with specific charges or items of expenditure, the levy and collection of which were governed by independent contractual or statutory provisions. Therefore, these decisions cannot go beyond what they deal with. Conclusion on the issue whether anti dumping duty would form part of the sale price 44. It should be poi .....

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itory outside the territory of India, cannot be extended beyond its purpose. The phrase used in Section 9-A of the Customs Tariff Act is "where any article is exported .... to India". 45. Therefore, the fact remains that the petitioner, though located in a Special Economic Zone, is nevertheless in India, to whom a company from China has exported goods. But, the petitioner enjoyed exemption from payment of anti dumping duty only because of being located in a Special Economic Zone. This .....

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since the point of first import was when the goods came to India from China. Assuming that the clearance of goods by the buyer of the petitioner, which happened at the gate of the Special Economic Zone is also equivalent to an import, it could be taken only to be a second incidence of import. Anti dumping duty was leviable on the first incidence of import. This is why the expression "leviable" appearing in Section 15 of the State enactment and Section 30 of the Central Special Economi .....

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e can be looked at from another angle also. The actual purpose of levy of anti dumping duty, as pointed out by the Supreme Court in Reliance Industries Ltd. v. Designated Authority [(2006) 10 SCC 368], is to maintain a level playing field for the domestic market, with the products that are exported into India. Tracing the history of the legislation providing for anti dumping duty, it was observed in Hyundai Motors India Ltd. v. Union of India (WP No.11683 of 2014 dated 12.12.2014), by one of us .....

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14 of 1994, to take effect from 01.01.1995, coinciding with the creation of the World Trade Organisation. 21. By Section 9-A inserted in the Customs Tariff Act, 1975, the Parliament empowered the Central Government to impose an Anti-Dumping Duty, when an article is exported by an exporter or producer from any country or territory to India, at less than its normal value. Sub-section (1-A) of Section 9-A of the Act also empowers the Central Government to extend the anti-dumping duty to such other .....

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nce it is established that there is (i) dumping, (ii) injury, and (iii) causal link between dumping and injury, anti dumping duty is levied. The margin of dumping is the difference between the normal value, namely the price in the domestic market of the foreign exporter and the export price at which the goods are exported to India. Therefore, once anti dumping duty is levied, the same becomes part of the sale price, as otherwise the sale price of the product imported into India will be different .....

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contention of Mr.C.Natarajan, learned senior counsel for the petitioner is that when there is a confusion or bona fide doubt with regard to the inclusion of an item in the sale price of a product or in the turnover, the levy of penalty should be avoided. In support of this contention, the learned senior counsel relied upon the decisions in Hindustan Steel Ltd. v. State of Orissa [(1969) 2 SCC 627], Union of India v. Rajasthan Spinning and Weaving Mills [(2009) 13 SCC 448] and Commissioner of Sa .....

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acious or dishonest or acted in conscious disregard of its obligation. The Court also pointed out that penalty will not also be imposed merely because it is lawful to do so. 52. In Rajasthan Spinning and Weaving Mills, the Supreme Court pointed out that the issues relating to (i) recovery, (ii) interest, and (iii) penalty are dealt with in Sections 11-A, 11-AA, 11-AB and 11-AC and that penalty under Section 11-AC is a punishment for the act of deliberate deception by the assessee with intent to .....

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t held that in examining whether mens rea is an essential element of the offence created under a taxing statute, regard must be had to (i) the object and scheme of the statute, (ii) the language of the Section, and (iii) the nature of penalty. 54. Insofar as the present case is concerned, the proceedings arose under the Tamil Nadu VAT Act, 2006. Penalty is leviable under Section 27(3), if certain conditions are satisfied. They are (i) the assessing authority should be satisfied, (ii) that the es .....

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umping duty itself was payable or not. Even before this doubt could be cleared, the petitioner themselves sought a clarification from the Assessing Officer vide letter dated 06.9.2010. Much before this clarification was issued, the company which purchased the finished product from the revision petitioner paid the anti dumping duty. Thereafter, the Assessing Officer issued a clarification dated 29.4.2011 to the effect that anti dumping duty is to be included in the sale price. Simultaneously, a s .....

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ere was wilful non disclosure of assessable turnover. In fact, no finding to this effect could have been recorded by the Assessing Officer in view of the fact that the whole thing was brought to the notice of the Assessing Officer by the petitioner themselves by their letter dated 06.9.2010 seeking a clarification. 57. Before the Appellate Deputy Commissioner, the assessee raised an objection with regard to penalty. In one paragraph, the Appellate Authority held that there was a wilful intention .....

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ion of penalty at the rate of 150% under Section 27(3)(c) of the TNVAT Act, 2006 is set aside. QUESTION-(iii) 59. The third question of law raised by the petitioner is as to whether on the facts and in the circumstances of the case, the learned Appellate Tribunal was correct in law in holding that the petitioner is not entitled to refund of tax inadvertently paid on countervailing duty discharged on the finished goods cleared from the petitioner's SEZ unit. 60. Before the first Appellate Aut .....

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e these are payable only by the buyer at the time of clearance of the goods, the wrongful payment of the same by the assessee should not be taken advantage of by the Department to take the customs duty as part of the turnover for the levy of Value Added Tax. 62. But, the Tribunal rejected the same on the same ground as the contention relating to anti dumping duty was rejected. Hence, the third question of law. 63. But, as we have pointed out earlier, the petitioner was the actual importer of the .....

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