F. No. V.69/15-338/Adj/2011 OIO 78 /Commr/2013 M/s Flora Ceramic Pvt Ltd Page 1 of 24 lhek “kq Yd ,oa ds Unz h; mRikn “kq Yd vk;q Drky;] ds Unz h; mRikn Hkou] js l dks lZ ] fja x jks M jktdk s V-360001 CENTRAL EXCISE & CUSTOMS COMMISSIONERATE CENTRAL EXCISE BHAVAN : RACE COURSE RING ROAD RAJKOT 360 001 Phone – (0281) 2442030, 2441980, 2441982 Fax – (0281) 2443313, 2452967 Email: [email protected]Qk- la - F.No. V.69/15-338/Adj/2011 By RPAD/HAND DELIVERY vkns ”k dh rkjh[k Date of order 17.07.2013 ew y vkns ”k la- ORDER IN ORIGINAL NO. 78/COMMR/2013 tkjh djus dh rkjh[k Date of Issue 18.07.2013 vkns ”kdrkZ Ordered by वी पƬनाभन vk;q Dr ds-m-“kq - vk;q Drky; jktdks V V. Padmanabhan Commissioner, Customs & Central Excise, Rajkot. ds la nHkZ es a In the case of M/s. Flora Ceramic Private Limited, 8-A, National Highway, Lakhdhirpur Road, Morbi 363642 dkj.k crkvks la- ,oa frfFk Show Cause Notice No. & Date V.69/AR-MORBI-DIV.II /32/ COMMR./2013 dated 26.02.2013 1. ǔजस åयǒƠ(यɉ) को यह Ĥित भेजी जाती है , उसे åयǒƠगत Ĥयोग के िलए िनःशुãक Ĥदान कȧ जाती है। This copy is granted free of charge for private use of the person(s) to whom it is sent. 2. इस आदेश से असंतुƴ कोई भी åयǒƠ इस आदेश कȧ ĤािƯ से तीन माह के भीतर सीमा शुãक, उ×पाद शुãक एवं सेवाकर अपीलीय Ûयायािधकरण, अहमदाबाद पीठ को इस आदेश के ǒवǽƨ अपील कर सकता है। अपील सहायक रǔजèĚार, सीमा शुãक, उ×पाद शुãक एवं सेवाकर अपीलीय Ûयायािधकरण,O-20, मेघाणीनगर, Ûयु मेÛटल हॉèपीटल कàपाउÛड, अहमदाबाद-380 016 को सàबोिधत होनी चाǑहए। Any person deeming himself aggrieved by this Order may appeal against this Order to the Customs, Excise and Service Tax Appellate Tribunal, Ahmedabad Bench within three months from the date of its communication. The appeal must be addressed to the Assistant Registrar, Customs, Excise and Service Tax Appellate Tribunal, O-20, Meghani Nagar, Mental Hospital Compound, Ahmedabad-380 016. 3. उƠ अपील Ĥाǽप सं . इ.ए.3 मɅ दाǔखल कȧ जानी चाǑहए। उसपर के Ûġȣय उ×पद शुãक (अपील) िनयमावली, 2001 के िनयम 3 के उप िनयम (2) मɅ ǒविनǑद[ƴ åयǒƠयɉ Ʈारा हèता¢र Ǒकए जाएंगे। उƠ अपील को चार ĤितयɈ मɅ दाǔखल Ǒकया जाए तथा ǔजस आदेश के ǒवǽƨ अपील कȧ गई हो, उसकȧ भी उतनी हȣ Ĥितयाँ
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F. No. V.69/15-338/Adj/2011 OIO 78 /Commr/2013 M/s Flora Ceramic Pvt Ltd
1. जस य (य ) को यह ित भेजी जाती है, उसे य गत योग के िलए िनःशु क दान क जाती है। This copy is granted free of charge for private use of the person(s) to whom it is sent. 2. इस आदेश से असंतु कोई भी य इस आदेश क ाि से तीन माह के भीतर सीमा शु क, उ पाद शु क एवं सेवाकर अपीलीय यायािधकरण, अहमदाबाद पीठ को इस आदेश के व अपील कर सकता है। अपील सहायक र ज ार, सीमा शु क,
उ पाद शु क एवं सेवाकर अपीलीय यायािधकरण,O-20, मेघाणीनगर, यु मे टल हॉ पीटल क पाउ ड, अहमदाबाद-380 016 को स बोिधत होनी चा हए। Any person deeming himself aggrieved by this Order may appeal against this Order to the Customs, Excise and Service Tax Appellate Tribunal, Ahmedabad Bench within three months from the date of its communication. The appeal must be addressed to the Assistant Registrar, Customs, Excise and Service Tax Appellate Tribunal, O-20, Meghani Nagar, Mental Hospital Compound, Ahmedabad-380 016. 3. उ अपील ा प सं. इ.ए.3 म दा खल क जानी चा हए। उसपर के य उ पद शु क (अपील) िनयमावली, 2001 के िनयम 3 के उप िनयम (2) म विन द य य ारा ह ता र कए जाएंगे। उ अपील को चार ितय म दा खल कया जाए तथा जस आदेश के व अपील क गई हो, उसक भी उतनी ह ितयाँ
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संल न क जाएँ (उनम से कम से कम एक ित मा णत होनी चा हए)। अपील से स बंिधत सभी द तावेज भी चार ितय म अ े षत कए जाने चा हए।
The Appeal should be filed in form No. E.A.3. It shall be signed by the persons specified in sub-rule (2) of Rule 3 of the Central Excise (Appeals) Rules, 2001. It shall be filed in quadruplicate and shall be accompanied by an equal number of copies of the order appealed against (one of which at least shall be certified copy). All supporting documents of the appeal should be forwarded in quadruplicate.
4. अपील जसम त य का ववरण एवं अपील के आधार शािमल ह, चार ितय म दा खल क जाएगी तथा उसके साथ जस आदेश के व अपील क गई हो, उसक भी उतनी ह ितयाँ संलगन क जाएंगी (उनम से कम से कम एक मा णत ित होगी)।
The Appeal including the statement of facts and the grounds of appeal shall be filed in quadruplicate and shall be accompanied by an equal number of copies of the order appealed against (one of which at least shall be a certified copy.) 5. अपील का प अं ेजी अथवा ह द म होगा एवं इसे सं एवं कसी तक अथवा ववरण के बना अपील के कारण के प शीष के अंतगत तैयार करना चा हए एवं ऐसे कारण को मानुसार मां कत करना चा हए। The form of appeal shall be in English or Hindi and should be set forth concisely and under distinct heads of the grounds of appeals without any argument or narrative and such grounds should be numbered consecutively. 6. अिधिनयम क धारा 35 बी के उपब ध के अंतगत िनधा रत फ स जस थान पर पीठ थत है, वहां के कसी भी रा ीयकृत बक क शाखा से यायािधकरण क पीठ के सहायक र ज ार के नाम पर रेखां कत माँग ा ट के
ज रए अदा क जाएगी तथा यह माँग ा ट अपील के प के साथ संल न कया जाएगा। The prescribed fee under the provisions of Section 35 B of the Act shall be paid through a crossed demand draft, in favour of the Assistant Registrar of the Bench of the Tribunal, of a branch of any Nationalized Bank located at the place where the Bench is situated and the demand draft shall be attached to the form of appeal. 7. यायालय शु क अिधिनयम, 1970 क अनुसूची-1, मद 6 के अंतगत िनधा रत कए अनुसार संल न कए गए आदेश क ित पर 5.00 पया का यायालय शु क टकट लगा होना चा हए। The copy of this order attached therein should bear a court fee stamp of Re. 1.00 as prescribed under Schedule 1, Item 6 of the Court Fees Act, 1970. 8. अपील पर भी . 5.00 का यायालय शु क टकट लगा होना चा हए। Appeal should also bear a court fee stamp of Rs. 5.00.
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Brief facts of the case:
M/s. Flora Ceramic Private Limited, 8-A, National Highway,
Lakhdhirpur Road, Morbi 363642 (hereinafter referred to as Noticee)
registered as manufacturer of various excisable goods falling under
the First Schedule to the Central Excise Tariff Act, 1985, vide
Registration No: AABFF6275FXM001, are availing the benefit of
Cenvat credit on the inputs and input services used by them as per
provisions of the Cenvat Credit Rules, 2004, to be used in or in
relation with the manufacture of their various final products.
2.1 During the course of Audit under EA-2000, under taken by the
Officers of Internal Audit Department, Hq. Rajkot on 23.12.2010, it
was noticed that Noticee had earned an income on account of sale of
Body Clay Powder. It was further revealed that the said material i.e.
Body Clay Powder emerged as an intermediate product during the
course of manufacture of their finished goods i.e. ceramic glaze tiles;
that the Body Clay Powder appears classifiable under Chapter Sub-
Heading No. 2530 90 99 of First Schedule to the Central Excise Tariff
Act, 1985 which attracts NIL rate of duty; that during the course of
manufacture of Body Clay Powder, the Noticee has availed Cenvat
credit on the inputs viz. Sodium Silicate, Soda Ash, etc. and has also
availed Cenvat credit of Service Tax paid on the inputs services viz.
Insurance and Goods Transport Agency Services used by them for
procurement of various raw materials viz. various types of clay,
They also relied upon the following case laws of Hon'ble Tribunal:
(i) COLLECTOR OF C. EX., PATNA Versus WAXPOL INDUSTRIES LTD-1996(85) ELT 132(T)
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Manufacture - Grinding of calcined bauxite and calcined
china day does not amount to manufacture as mere change
in form is not sufficient to hold an article to be a new
commercial commodity - Section 2(f) of Central Excises and
Salt Act, 1944 - Chapter 26 of Central Excise Tariff, [para 7}
Calcined bauxite powder and calcined china clay powder
obtained by the process of grinding the calcined bauxite and
calcined china clay respectively not liable to duty as no
process of manufacture involved in changing the physical
form of an article by grinding - Section 2(f) of Central Excises
and Salt Act, 1944 - Chapter 26 of Central Excise Tariff, [para
7]
(ii) WOLKEM INDIA LIMITED Versus COLLECTOR OF CENTRAL EXCISE, JAIPUR-1997 (92) E.L.T. 219 (Tribunal) [maintained by Hon'ble Supreme Court - 1998 (102) E.L.T. A224 (S.C)]
Manufacture - Mere powdering of lumps not amounts to
manufacture as no new commodity having come into existence
~ Section 2(f) of Central Excise Act, 1944.
- Undisputedly, the minerals are obtained by mining
operations in the form of lumps and all that is done is to crush
them into powder. The appellant has shown with the help of
the test report and affidavit also that the material remains
the same before and after grinding or crushing and its
character, composition and use remains basically the same. In
other words, no new commodity had come into existence.
Apex Court held that “so long as a new and distinct commodity known
in the market has come into existence there is manufacture.” The
Hon’ble Supreme Court in the case of Moti Laminates Pvt. Ltd.
Versus Collector of Central Excise, Ahmedabad - 1995 (76) E.L.T. 241
(S.C.) held as under.
“7. The duty of excise being on production and manufacture
which means bringing out a new commodity, it is implicit that
such goods must be useable, moveable, saleable and marketable.
The duty is on manufacture or production but the production or
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manufacture is carried on for taking such goods to the market for
sale. The obvious rationale for levying excise duty linking it with
production or manufacture is that the goods so produced must be
a distinct commodity known as such in common parlance or to the
commercial community for purposes of buying and selling.”
I find that the impugned goods viz, ‘Body Clay Powder’ is well known
in trade parlance as a distinct commercial commodity and is being
sold and purchased in the market.
24.3. I find that Note 1 to Chapter 25 of Schedule to Central Excise
Tariff Act, 1985, which falls under Section V – Mineral Products,
includes Salt; Sulphur; earths and stone; plastering materials, lime
and cement, clearly covers the product that:
(i) is in crude state
(ii) has been washed
(iii) crushed and powdered
Further, Note 4 to Chapter 25 of first schedule to Central Excise Tariff
Act, 1985, clearly stipulates that Heading No: 2530 covers the
products which are earth materials, whether or not calcined or mixed
together. As body clay powder is prepared by mixing various
clays/minerals and also containing two Cenvatable inputs - STPP and
Sodium Silicate, I am of the opinion that the said body clay powder
has emerged as an excisable goods appropriately classifiable under
Chapter Sub-Heading No: 25309099 of first schedule to Central
Excise Tariff Act, 1985. I also find that various case laws cited by the
noticee as mentioned in para supra with regard to manufacturing do not
embrace any aspect of the present case.
25.1 The Noticee has contended that since 'Body Clay Powder' does
not fall under the definitions of Section 2(f) of the Central Excise Act,
1944 and Rule 2(d) of the CCR, 2004, therefore, Rule 6 of CCR,
2004 is not applicable to them. Accordingly, they have
reversed credit availed on inputs/input services contained in
‘Body Clay Powder’ under sub rule (5) of Rule 3 of the CCR,
2004.
25.2 The discussions hereinabove has established that the
Noticee has manufactured ‘Body Clay Powder’ classifiable under
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Chapter Sub-Heading No: 25309099 of First schedule to Central
Excise Tariff Act, 1985, which attracts NIL rate of duty. Therefore, it is
evident that ‘Body Clay Powder’ is not cleared by the Noticee as
such, hence, case on hand is not covered under Rule 3(5) of Cenvat
Credit Rules, 2004. Further, I find that the Rule 6(1) of Cenvat Credit
Rules, 2004 stipulates that CENVAT credit shall not be allowed on
such quantity of input and input services used in or in relation to the
manufacture of exempted goods except in the circumstances
mentioned in sub-rule (2) of Rule 6 of Cenvat Credit Rules, 2004,
which places the onus on the manufacturer who avails of CENVAT
credit in respect of any inputs or input services and manufactures
such final products which are chargeable to duty or tax as well as
exempted goods to maintain separate account. I find that by not
maintaining separate account under provisions of Rule 6(2) of Cenvat
Credit Rules, 2004, the Noticee has rendered themselves under an
obligation to pay an amount equivalent to 10% of the value of the
exempted goods cleared prior to 07.07.2009 and 5% of the value of
the exempted goods cleared after 07.07.2009 in terms of Rule 6(3) (i)
of Cenvat Credit Rules, 2004. I find that the Noticee had not exercised
the option as provided under Rule 6(3A) of Cenvat Credit Rules, 2004.
Therefore, the Noticee has no option except to pay amount at the
prescribed rate of 10%/5% of the value of exempted goods under Rule
6(3) (i) of Cenvat Credit Rules, 2004. As the Noticee did not discharge
their liability as per provisions of Rule 6 (3)(i) of Cenvat Credit Rules,
2004, the same is liable to be recovered under Rule 14 of the Cenvat
Credit Rules, 2004 read with Section 11A of the Central Excise Act,
1944 alongwith interest under Section 11AA (erstwhile 11AB) of the
Central Excise Act, 1944.
26. Further, I find that the said Body Clay Powder was removed
without payment of the amount at the rates prescribed in Rule 6 (3)(i)
of Cenvat Credit Rules, 2004, as required as per Explanation-II of
Rule 6 of Central Excise Rules, 2004 as it stood prior to 31.03.2011,
hence, there is violation of provisions of Rule 4 and Rule 11 of Central
Excise Rules, 2002. Also, the Noticee has failed to assess the goods as
per provisions of Rule 6 of Central Excise Rules, 2002. Since the
goods were removed in contravention of the provisions of Rule 4 and
Rule 6 of Central Excise Rules, 2002, therefore, the amount at the
rates prescribed in Rule 6(3)(i) of Cenvat Credit Rules, which is a
Cenvat Credit (and in accordance with Section 2A of Central Excise
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Act, 1944, is a duty of Central Excise required to be paid under Rule 8
of Central Excise Rules, 2002) has not been paid. The fact of
emergence of the said body clay powder at the intermediate stage, its
sale by them without cover of valid Central Excise invoices, availment
of Cenvat credit on the inputs and inputs services used in or in
relation with manufacture of the said body clay powder, non
maintenance of separate records as per Rule 6(2) of Cenvat Credit
Rules, 2004 and not intimating the fact of non maintenance of
separate records to the department is in violation of Rule 12 of
Central Excise Rules, 2002. This fact came on record only when the
audit was conducted. Therefore, I find that the Noticee had
deliberately suppressed the material facts from the department with
an intention to evade payment of an amount under rule 6(3) of Cenvat
Credit Rules, 2004, as amended. Hence, I find that this is a fit case for
invoking the extended period of five years under proviso to Section
11A of the Central Excise Act, 1944 to recover the government-dues
not paid. I also find that by acting in the manner as aforesaid, the
said Noticee is also liable to penalty under Rule 15 of the Cenvat
Credit Rules, 2004 read with Section 11AC of the Central Excise Act,
1944.
27.1 The Noticee submitted that the government, to overcome
the above situation, had amended retrospectively provisions of
erstwhile Central Excise Rules, 1944, CENVAT Credit Rules, 2001,
CENVAT Credit Rules, 2002 and present CCR, 2004 with effect from
01.09.1996. In the instant case, Section 73 read with 8th Schedule of
the Finance Act, 2010 amending Rule 6 of CCR, 2004 is relevant and
accordingly the Noticee had paid an amount equal to CENVAT Credit
attributable to 'Body Clay Powder’ and no further amount is
required to be paid.
27.2 I find that Section 73 of the Finance Act, 2010 amended rule 6
of the Cenvat Credit Rules, 2004 in the manner specified in column
(3) of the Eighth Schedule with retrospective effect, on or from and
upto the date specified in column (4) thereof, so as to provide for
payment by manufacturer of an amount equal to CENVAT credit
attributable to inputs or input services used in or in relation to
manufacture of exempted goods or goods chargeable to nil rate of duty
before or after clearance of such goods along with interest at the rate of 24% per annum. I find that the said amendment applies to the
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cases in respect of which a dispute relating to adjustment of credit on
inputs in or in relation to exempted final products relating to the
period beginning on 10th day of September, 2004 to 31st day of
March’2008 (both days inclusive) was pending on the date on which
the Finance Bill, 2010 received the assent of the President. In the
present case, the Noticee has failed to take recourse to such
amendment and from the plain reading of amendment made vide
Finance Act, 2010, it was one time opportunity and the noticee has
failed to avail the same. Also, these changes have taken effect from
8th May, 2010 on enactment of the Finance Bill, 2010 and it is
expressly provided that these provisions apply only to such cases
where the disputes are pending as on the day the Finance Bill, 2010
is enacted. For brevity and to be more specific, I reproduce the
amendments made vide Finance Act, 2010:
The Eighth Schedule to the Finance Act, 2010 is as follows:
THE EIGHTH SCHEDULE
[See Section 73(1)]
S. No.
Provisions of CENVAT Credit Rules, 2004 to be amended
Amendment Period of effect of amendment
(1) (2) (3) (4)
Rule 6 of the Cenvat Credit Rules, 2004 as published vide notification no. G.S.r. 600(E), dated the 10th Septemeber, 2004 [23/2004-CE(NT), dated the 10th Septemebr’2004]
In the CENVAT Credit Rules, 2004, in rule 6, after sub-rule (6), the following sub-rule shall be inserted, namely: ‘(7) Where a dispute relating to adjustment of credit on inputs used in or in relation to exempted final products relating to the period beginning on 10th day of September, 2004 and ending with the 31st day of March’2008 (both days inclusive) is pending on the date on which the Finance Bill, 2010 receives the assent of the President, then notwithstanding anything contained in sub-rule (1) and (2), and clauses (a) and (b) of sub-rule (3), a manufacturer availing CENVAT credit in respect of any inputs or input services and manufacturing final products which are chargeable to duty and also other final products which are exempted goods, may pay an amount equivalent to CENVAT credit attributable to inputs or input services used in, or in relation to the
10th day of September, 2004 to 31st day of March, 2008 (both days inclusive)
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manufacture of , exempted goods before or after the clearance of such goods: Provided that the manufacturer shall pay interest at the rate of twenty-four percent per annum from the due date till the date of payment of the said amount. Explanation – For the purpose of this sub-rule, “due date” means the 5th day of the month following the month in which goods have been cleared from the factory.’
27.3 It is evident from the above that the said changes by way of
insertion of sub-rule (7) to rule 6 of the Cenvat Credit Rules, 2004
were effective only for the period upto 31.03.2008 (column (4) of the
Eighth Schedule to the Finance Act, 2010 as aforesaid refers). Hence,
the provisions of sub-rule (3) to rule 6 of the Cenvat Credit Rules,
2004 are applicable for the period from 01.04.2008 onwards. In
accordance with the said provision, the noticee in the given situation
was liable to pay an amount equal to 10%/5% of the value of the
exempted goods so manufactured and cleared by them during the
notice period. Also, they would have had the option to pay amount
equivalent to the Cenvat credit attributable to inputs and input
services used in, or in relation to, the manufacture of exempted goods
as per rule 6(3)(ii) of the said rules, had they intimated the
jurisdictional Superintendent of Central Excise as envisaged in rule
6(3A)(a) of the said rules. The Noticee failed in complying with the said
requirement of rule 6(3A)(a) of the said rules. Hence, they are left with
no other option than to comply with rule 6(3)(i) of the said rules, i.e.,
to pay an amount equal to 5%/10% of the value of the exempted
goods.
28.1 The Noticee has requested for correction in demand of duty in
the impugned show cause notice as rate of 10% instead of 5% on
the value of 'Body clay powder' sold after 07.07.2009 and upto
31.07.2009 has been applied. They submitted that in the month of
July 2009, out of five bills issued in that month, four bills for an
amount of Rs.18,11,603/- were issued after 07.07.2009 and
accordingly the demand ought to have been reduced by Rs.90,580/-.
These details have been confirmed by the Range Superintendent. I,
therefore, drop the demand of amount of Rs.90,580/- .
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28.2 The Noticee’s contention that even if it is considered that
they are required to pay an amount as per the provisions of Rule 6(3)
of CCR, 2004, the demand of Education Cess and Secondary
and Higher Education Cess on the amount of 5% and 10% is
beyond the provisions of said rule and addition of amount of
Rs.1,11,552/- (2% Education Cess) and Rs.55,776/- (1%
Secondary and Higher Education Cess) in demand, is totally wrong.
I find that Rule 6(3) of CCR, 2004 is very much clear and the
manufacturer is required to pay an ‘amount’ equal to 10%/5% of the
exempted goods. Thus, the demand of ‘amount’ should be to the extent of
10%/5% of the value of exempted goods only and demand of 2% E.Cess
& 1% HSEC is required to be dropped. As regards, Service tax paid by
the Noticee of Rs.4,87,521/- on input services along with interest of
Rs.99,500/- has no relevance with the demand of amount under Rule
6(3) of CCR, 2004.
29. In view of the above, I pass the following order:
: ORDER :
(i) I order to classify ‘body clay powder’ under Tariff Item No:
25309099 of first schedule to the Central Excise Tariff Act,
1985;
(ii) I confirm the demand of the amount of Rs.54,87,067/- (Rupees
Fifty Four Lac Eighty Seven thousand Sixty Seven only) under
sub Rule (3) of Rule 6 of the Cenvat Credit Rules, 2004 and
under Rule 14 of the Cenvat Credit Rules, 2004 read with
Section 11A of Central Excise Act, 1944. As an amount of
Rs.7,17,014/- already paid by the noticee towards reversal of
amount vide Challan No:00010 dated: 12.05.2011, I order to
appropriate the same;
(iii) I drop the excess demand of Rs.90,580/- as discussed above at
para 28.1.
(iv) I drop the demand of Rs.1,11,552/- (2% Education Cess) and
Rs.55,776/- (1% Secondary and Higher Education Cess) as
discussed above at para 28.2.
F. No. V.69/15-338/Adj/2011 OIO 78 /Commr/2013 M/s Flora Ceramic Pvt Ltd
Page 24 of 24
(v) I order to recover the interest at appropriate rate under Section
11AA (erstwhile 11AB) ibid. As an amount of Rs.1,21,316/-
already paid towards interest, I order to appropriate the same;
and
(vi) I impose a penalty of Rs.54,87,067/- (Rupees Fifty Four Lac
Eighty Seven thousand Sixty Seven only) upon them under
Rule 15 of the Cenvat Credit Rules, 2004 read with Section
11AC of Central Excise Act, 1944. The said noticee can avail the
option of payment of 25% of Central Excise Duty as penalty
under Section 11AC of the Central Excise Act, 1944, if the
Central Excise Duty determined under Section 11A and interest
at applicable rate under Section 11AA of the Central Excise Act,
1944 is paid within 30 days from the date of receipt of this
order. The benefit of reduced penalty shall be available only if
the amount of penalty so determined has also been paid within
the period of 30 days from the receipt of this order.
Show Cause Notice No. V.69/AR-MORBI-DIV.II/32/COMMR./2013
dated 26.02.2013 is decided accordingly.
F. No:V.69/15-338/Adj/2011 (V.Padmanabhan) Date :18.07.2013 COMMISSIONER, Central Excise and Customs , RAJKOT.
Copy to: 1. The Chief Commissioner, Central Excise, Ahmedabad 2. The Deputy Commissioner, Central Excise, RRA, Rajkot 3. The Assistant Commissioner, Central Excise, Audit, Rajkot 4. The Assistant Commissioner, Central Excise, Division-II, Rajkot. 5. The Superintendent, Central Excise, AR-Morbi. 6. Guard File