TMI Blog2017 (2) TMI 90X X X X Extracts X X X X X X X X Extracts X X X X ..... ion raised by the appellants. It has been claimed that the clearance to SEZ have taken place under CT-3 and AR-3 documents and therefore, were within the knowledge of revenue. It is also claimed that part of the demand is for the period beyond five year. The impugned order does not deal with the issues - appeal is allowed by way of remand for comprehensive examination of issues raised by the appel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vide letter dated 15/12/2016 to decide the case on merits based on the grounds of appeal memorandum. 3. In the appeal memorandum it has been argued that the raw materials on which reversal of credit has been sought were still lying in the factory and were not written off in the records and were not destroyed as waste or refuse. It has been argued that the credit has been reversed under coercion ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Notification No.67/95. It has been argued that so called intermediate products have been cleared only a final product of the appellant supplied to SEZ. The demand has also been contested on the ground of limitation. It has been argued that clearance covered by CT3 certificate and AR3 were within the knowledge of the revenue. Hence, extended period could not have been invoked. It has also been ..... X X X X Extracts X X X X X X X X Extracts X X X X
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