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TMI Blog2024 (7) TMI 1312X X X X Extracts X X X X X X X X Extracts X X X X ..... Maroria, AOR Mr. T.S. Sabarish, Adv. Ms. Monica Baenjamin, Adv. Ms. Aakansha Kaul, Adv. Mr. Adit Khorana, Adv. Mr. Rupinder Sinhmar, Adv. Mr. Rupesh Kumar, Adv. Mr. Kritagya Kait, Adv. Mr. G. S. Makker , Adv For the Respondent : Mr. P.P. Malhotra, Sr. Adv. Mrs. Sonia Malhotra, Adv. Mr. Gaurav Sharma , AOR ORDER 1. We have heard learned counsel for the appellant as well as learned counsel for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... milar activities were not paying excise duty and were instead registered as traders. Consequently, on 23.11.2006, the respondent-assessee wrote to the Assistant Commissioner, Central Excise Division, Patiala, expressing their intention to surrender their manufacturing licence and obtain a trading licence for hydrogen gas. According to the respondentassessee, the compression and bottling of hydroge ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... filling and marketing of hydrogen gas cylinders with labels constituted manufacturing as per Chapter Note 9 of Chapter 28. This led to the issuance of a show cause notice dated 08.10.2010 invoking the extended period of limitation, raising a demand of Rs. 3,17,82,267/- in excise duty and proposing an equal amount as a penalty. The respondent-assessee contested this notice, arguing that their activ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... stant case, the process involved is that the gas received by the appellant through the pipeline has some accumulation of moisture and in order to remove the same from the gas, the compressor has an inbuilt system of drying the moisture. The treatment employed by the respondent-herein is oil filtration for the removal of moisture from gas by drying the inbuilt system of compressing gas into the cyl ..... X X X X Extracts X X X X X X X X Extracts X X X X
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