Chartered Accountant
Bookmark and Share
click here to subscribe our newsletter
 
 
Corporate News *  The GSTN has issued an Advisory dated 21.04.2026 about the introduction of an Offline Tool for the Invoice Management System (IMS)  *  CBIC extends due dates for filing of FORM GSTR 3B  for the month of April 2026 *  Interest cannot be imposed in adjudication order, if not demanded/quantified in show cause notice : Allahabad HC *  Wheelchairs with toileting facility eligible for exemption: CESTAT affirms customs duty exemption to importer *  Industries urge GST council to allow inverted duty refunds on input services *  Tamil Nadu GST dept introduced virtual hearing facility for GST appeals under under section 107 of the TNGST act: detailed guidelines  *  CIC urges authorities to implement GST evasion complaint tracking system *  Even if the assessee opts "NO" for personal hearing in form DRC-06 ,The mandatory requirement under section 75(4) to grant opportunity of hearing cannot be waived:Gujarat High Court  *  Glufosinate imports curbs imposed by govt *  Government extends Re-import period for exported cut & polished diamonds *  CIC flags lack of tracking system for tax evasion complaints,urges GST authorities to improve transparency *  No Custodial Interrogation needed in GST fraud case based on documentary evidence already in Department's Possession : Chattisgarh HC *  Orders under section cannot be sustained if passed without considering the taxpayer's objections and without granting a personal hearing:Gujarat High Court *  Mere cancellation of supplier's registration cannot,by itself,justify denial of ITC or cancellation of the recipient's registration:Bombay High Court *  High Court sets aside GST notice citing factual errors and natural justice violations *  Provisional Bank Attachment under Section. 110 of Customs Act Unsustainable Beyond Statutory period without Extension order: Bombay HC orders to defreeze accounts *  Post Clearance MRP Alteration by Distributor Does not attract Differential Customs Duty: CESTAT *  DGFT Expands scope of 'Screws' classification under RoDTEP Scheme  *  E-way bills surze to all time high of 140.6 million in March *  GST Exemption Allowed on Pure Labour Services for Standalone Houses: AAR  *  GST Payable Only on Margin in Second-Hand Car Sales, Subject to Strict Conditions and No ITC Claim: AAR *  DGFT rolls out procedure for allocation of calcined coke *  GST portal update : Pre-deposit amount now editable in Appeals *  J&K HC declared TMT scrap a 'Specified Good' eligibile for GST refunds under Support Scheme  *  Pigmy agents are employees of banks; no GST can be levied on commission  paid to them : Karnataka HC *  DGFT Revises HS Code Description for Screws Under RoDTEP *  GST Registration Cancellation Invalid Without Proper Service of Notice: Allahabad High Court. *  Bengaluru CGST | GST Backlog Appeals Deadline Fixed at June 30, 2026 *  No Time Bar on Refund of Service Tax for Services Not Rendered: CESTAT  Remands Indiabulls Case for Unjust Enrichment Check. *  Supreme Court Holds Renewable Energy Incentive Must Benefit Generators, Not Be Adjusted in Tariff
Subject News *   Delhi HC Quashes Order, Says Reminder Cannot Validate Improperly Served GST SCN *  KARNATAKA HIGH COURT REMANDS GST SHORTFALL MATTER DUE TO ABSENCE OF PERSONAL HEARING   *  CESTAT cancels confiscation and penalties on imported computer cabinet cases: Custom duty restricted to 111 surplus units *  Deposit of tax during search or investigation cannot be treated as 'Voluntary Payment' : Bombay High Court *  Section 76 of the CGST cannot be invoked where the tax has already been duly deposited, even if through another registration of the same entity: Madras High Court *  Sec 74 allows use of material regardless of source; illegality or flaws in section 67 search do not vitiate valid adjudication: HC *  Inter-State transfer of ITC on Amalgamation permissible as given under section 18(3) read with rule 41 of the CGST rules, 2017: Gujarat High Court *  HC: No GST on commisson paid to Pigmy Agents *  IGST refund denial on illegible bill of lading invalid absent chance to furnish docs; merit reconsideration in appeals directed: HC *  ITC is not admissible on GST paid on leasehold rights of land used fpr setting up an air seperation plant: AAAR,Tamil Nadu *  GST: No penalty under Section 74 after voluntary ITC reversal due to non-existent supplier : High Court *  TN AAAR denies GST ITC on Land Lease under Sec. 17(5)(d) for setting up plant and machinery *  GST proceedings quashed as notices sent to old address, despite updated address in registration *  Importer Can’t Be Penalised for Alleged IGCR Procedural Lapses Without Evidence of Departmental Error: CESTAT *  Structured Healthcare Training Not ‘Charitable Activity’, 18% GST Payable: AAR  *  CESTAT As The Appellate Authority For Central Sales Tax Disputes: A Paradigm Shift Under Finance Act, 2023 *   Rs. 25K Cost Imposed On SGST Joint Commissioner for Attaching Bank  Accounts Without Forming Mandatory “Opinion”: Bombay HC *   Ex-Parte GST Order Without Hearing Violates Natural Justice: Karnataka  High Court Quashes Adjudication and Bank Attachment.  *   Retrospective GST Cancellation Can’t Invalidate Genuine Transactions:  Jaipur Commissioner (Appeals) Quashes Rs. 95,670 ITC Demand. *   GST Pre-Deposit Non-Compliance: Allahabad High Court Allows Appeal  Subject to Rs. 30 Lakh Balance Deposit, Recognises Offline Filing. *  Documentary Nature of Evidence: Allahabad High Court Grants Bail in Rs. 32.66 Crore Fake ITC Fraud Case *  Supreme Court Flags Systemic Bias in Army’s Permanent Commission Process for Women Officers *  Re-Determination of Land Compensation Can Be Based on Appellate Court Awards, Clarifies Scope of S. 28-A: Supreme Court. *  Supreme Court Imposes Rs. 5 Lakh Costs On Rent Authority Officer For Acting Beyond Jurisdiction. *  DGGI Meerut | Court Denies Bail to Accused in Claiming Fake ITC And Export Refunds *  Denial of GST Rate Revision Benefit to Contractor Violates Article 14: Rajasthan HC *  GST Registration Cancellation for Non-Filing of Returns: Gauhati High Court Directs Restoration on Compliance. *   Supreme Court Quashes FEMA Adjudication Orders, Revives Proceedings at  Show Cause Stage. *   Higher Rank, Harsher Punishment Justified: Supreme Court Restores Dismissal  of Bank Manager in Misappropriation Case. *   Limitation for Export Refund to Be Counted from Foreign Exchange Realisation,  Not From Export Invoices Issuance: CESTAT  

Comments

Print   |    |  Comment

PJ/Case law/2014-15/2252

Whether credit availed on modification of machines that does not amounts to manufacture proper?

Case:- COMMISSIONER OF CENTRAL EXCISE, BALGAUM Versus  S.R.V. AUTOMOBILE

Citation:- 2014 (299) E.L.T. 301 (Kar.)

Brief facts:-This appeal is by the Revenue being aggrieved by the order passed by the Customs, Excise and Service Tax Appellate Tribunal, South Zonal Bench, Bangalore, in Final Order No. 2086/20069, dated 22-12-2006 [2007 (211) E.L.T. 346 (Tribunal)] wherein the Tribunal has held that there was no suppression of fact and therefore extended period of limitation could not be invoked by the Revenue under Section 11A of the Act and wherefore the claim was barred by limitation and allowed the appeal filed by the assessee by setting aside the order passed by the appellate authority and the adjudicating authority.

Necessary material facts to answer the above said substantial question of law are as follows:

Respondent-assessee are holders of Central Excise Registration and are engaged in manufacture of conveyors and parts thereof, industrial washing machine and parts thereof, falling under Chapter 84 of the Central Excise Tariff Act, 1985. The assessee had received 3 nos. Girija brand industrial washing machines from M/s. TVS Suzuki limited, for the purpose of refurbishing and modification. These 3 washing machines were cleared vide their invoice No. 43303, dated 1-2-2001 on payment of duty of Rs. 2,61,760/- at the rate of 16%. Since it was found that assessee is not eligible to take Cenvat credit on such goods, which are not raw material or input nor capital goods for the manufacture of the final products and in refurbishing and modification of the washing machines and assessee was not involved in the activity of manufacture, assessee could not have availed Cenvat credit on 3 washing machines and the assessee had availed Cenvat credit of Rs. 2,61,760/- on three old industrial washing machines based on the Invoice No. 43303, dated 1-2-2001 knowingly that they had received only for repair/modification and return purpose. Therefore, assessee has availed Cenvat credit wilfully by suppressing the material facts and also enabled the consignee to take irregular Cenvat credit based on their invoices bearing Nos. 48 and 49 both dated 23.8-2001 and wherefore show cause notice was issued on 28-7-2004 by the adjudicating authority - Assistant Commissioner of Central Excise, Hubli Division, Hubli to show cause as to why the said Cenvat credit of Rs. 2,61,760/- availed irregularly should not be demanded and recovered and the duty debited vide Invoice Nos. 48 and 49 both dated 23-8-2001 and differential amount of Rs. 39,472/- debited by Entry No. 187, dated 16-12.2002 in RC-23A Part-ll should not be appropriated under the proviso (1) of Section 11A of the Central Excise Act, 1944 read with Rule 12 of the Cenvat Credit Rules and duty of Rs. 56,232/- should not be demanded and recovered under the proviso to Section 11A(1) of Central Excise Act, 1944, read with Rule 8 of Central Excise Rules, 2002 proposing the preliminary actions 1 to 3.

In response to the said show cause notice, assessee filed his reply contending that there was no suppression of material facts and wherefore the Revenue could not have invoked extended period of limitation. There was manufacturing activity and  there was no intention to evade payment of excess duty and they have not evaded any central excise duty and not contravened any provisions of central excise law and the issue covered under the show cause notice is one of the matters involving interpretation of law. Hence, no penalty can be imposed on them. The objections were overruled and the adjudicating authority by order dated 2-3-2005 passed the order-in-original as follows :
 
"1. The Modvat/Cenvat credit of Its. 2,61,760/- availed by the assessees is treated as ineligible and I demand the same under the proviso to Section 11A(1) of the Central Excise Act, 1944 read with Rule 12 of Cenvat Credit Rules, 2002.

2. I appropriate duty of Rs. 80,154/- and Rs. 1,42,134/- debited and paid vide invoice Nos. 48 and 49 both dated 23-8-2001 respectively against the demand 1 above.

3. I also appropriate the differential ineligible Modvat/Cenvat credit of Rs. 39,472/- which was paid and debited vide Cenvat account Entry No. 187, dated 16-12-2003 against demand 1 above.

4. I demand duty of Rs. 65,232/- on the total value of new spares used in the repair/refurbishing of 3 Nos. old industrial washing machines under the proviso to Section 11A(1) of the Central Excise Act, 1944.

5. I demand the interest at the appropriate rate on the demand ordered against 1 and 4 above under Section 11A8 read with Rule 12 of Cen-vat Credit Rules, 2002.

6. I impose penalty of Rs. 65,232/- under Section 11AC of the Central Excise Act, 1944 for the demand ordered against demand I and 4 above.

7. I impose a penalty of Rs. 2,000/- under Rule 25 of Central Excise Rules, 1944."
 
The said order was taken in Appeal No. 250/2005 before the Commissioner of Central Excise (Appeals), Mangalore in Appeal No. 72/2005(BM)/3079 and the appellate authority confirmed the order passed by the adjudicating authority and being aggrieved by the same, assessee has preferred an appeal in Appeal No. Excise/1091/2005 before the Customs, Excise and Service Tax Appellate Tribunal, South Zonal Bench. Bangalore (hereinafter referred to as "CESTAT") and the Tribunal by order dated 22-12-2006 held that since there was no suppression of facts, they availed Cenvat credit and cleared the goods on payment of duty and the same was disclosed to the department. The internal audit party had checked the records during 2002 and they did not find any discrepancy. Therefore reopening the issue after a lapse of three years on the ground that the clearances are to be reassessed at the higher rate is clearly barred by time. There was no intention to evade payment of duty and wherefore, the appeal was allowed by holding that since there was no suppression of fact, confirmation of value addition is not sustainable and the same is barred by time and accordingly allowed the appeal with consequential relief. Being aggrieved by the order passed by the CESTAT, this appeal is filed by the Revenue which has been admitted for consideration of the above substantial question of law.

Appellant’s contention:- Learned counsel appearing for the appellant-Revenue submitted that there was suppression of facts on which there is concurrent finding by the adjudicating and appellate authority. The material on record would clearly show that though no manufacturing activity was involved in refurbishing and modification of the washing machines, Cenvat credit was availed and though excess duty has been collected the same is suppressed. Raised excess duty has been credited and wherefore, the Tribunal was not justified in setting aside the concurrent finding by holding that the invoking of Section 11A is barred by time and therefore the order passed by the Tribunal is liable to be set aside.

Reasoning of judgment:-Having heard the learned counsel appearing for the appellant, learned counsel appearing for the respondent has not appeared though the matter was adjourned from time to time to give an opportunity to the counsel appearing for the respondent to argue the matter and by order dated 20th April, 2011 since the counsel for the respondent was absent, as a last chance the matter was adjourned to 25-7-2011 and thereafter matter was again adjourned to 29-7-2011 and thereafter it is posted for 11-8-2011 for final hearing and the counsel appearing for the respondent is not present.

Having  given careful consideration to the contentions of the learned counsel for the appellant, it is concluded that the material on record would clearly show that there is suppression of fact as it clear from the order passed by the adjudicating authority and the appellate authority that there was no manufacturing activity involved in refurbishing and modification of the washing machines, despite the same, Cenvat credit was claimed and though duty of Rs. 2,61,760/- was collected, the said fact was suppressed and therefore availed extended period of limitation. In view of the decision of the Hon'ble Supreme Court in Mysore Rolling Mills Private Limited v. Collector of Central Excise, Belgaum - 1987 (28) E.L.T. 50 (S.C.), wherein it has been clearly held that non-disclosure of receipt of such amount at the time of assessment extended period of 5 years applicable and Rule 10(1)(C) of the Central Excise Rules, 1944, corresponding to Section 11A of the Central Excises and Salt Act, 1944. Thus extended period was applicable. Hence, the show cause notice issued after one year was not barred by limitation under Central Excises and Salt Rules wherein provision is identical to the provisions under the Central Excise Act.

The Tribunal has not at all considered the reasoning assigned by the adjudicating authority and the appellate authority in holding that there is no suppression of material facts and thus has proceeded to set aside the order passed by the appellate authority and by holding that there is no suppression of fact which is baseless and based on conjuncture and surmises and not based up-on the material on record, the High Court answered the substantial question of law in favour of the Revenue and pass the following order : The appeal is allowed. The order dated 22-12-2006 passed by the CESTAT in Appeal No. Excise 1091/2005 is set aside and the matter is remitted to CESTAT for consideration of the appeal on merits and in accordance with law.

Decision:- Appeal allowed.

Comment:-The crux of the case is that when assessee has done only modification in the machines and it is known that such an activity does not amounts to manufacture and even then the credit is being availed on the washing machines at the time of their receipt, then it is clear case of suppression of fact and in this case extended period of 5 years will be applicable to issue the show cause notice as per Section 11A (4) of the Central Excise Act,1944. Accordingly, it was concluded by the High Court that there was suppression of facts and the extended period of limitation was invokable because credit was availed even when there was no manufacturing activity done by the assessee.

Prepared by: Kushal Shah
 
 
 
 
 
 
 
 
 

Department News


Query

 
PRADEEP JAIN, F.C.A.

Head Office : -

Address :
"SUGYAN", H - 29, SHASTRI NAGAR, JODHPUR (RAJ.) - 342003

Phone No. :
0291 - 2439496, 0291 - 3258496

Mobile No. :
09314722236

Fax No. :0291 - 2439496


Branch Office : -

Address:
1008, 10th FLOOR, SUKH SAGAR COMPLEX,
NEAR FORTUNE LANDMARK HOTEL, USMANPURA,
ASHRAM ROAD, AHMEDABAD-380013

Phone No. :
079-32999496, 27560043

Mobile No. :
093777659496, 09377649496

E-mail :pradeep@capradeepjain.com