2017 (6) TMI 666

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..... hok Jindal The Revenue is in appeal against the impugned order. 2.   The facts of the case are that the respondent is engaged in manufacturing of ISI marked diesel engines sets schemes were listed for farmers to install diesel engine sets for which Primary Agriculture Development Banks will give loan to the farmers and procedure was as such that piece of land as shown in 'JAMABANDI' sh .....

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..... es of diesel engine set and also sold loose kits. It is his further submission that they have availed to SSI Exemption limit, they have not obtained registration from the department and the invoices issued by the dealers to the farmers shows that the diesel engine sets are manufactured by the respondent is not correct, as the dealers themselves had assembled the loose kits and selling them to the .....

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..... ;  I find that during the course of investigation, the dealers have stated that either they have issued only invoices to the farmers to clearing loan from the banks or in most of the cases they have purchased loose kits from the respondent and, thereafter, assembled the same sold to the farmers where the dealers have assembled the diesel engine sets, in that case, dealers became the manufactu .....

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