Custom, Excise & Service Tax Tribunal
M/S. Raymond Ltd vs Commissioner Of Central Excise, ... on 19 October, 2011
IN THE CUSTOMS, EXCISE AND SERVICE TAX APPELLATE TRIBUNAL
WEST ZONAL BENCH AT MUMBAI
COURT NO.1
APPEAL NO.E/1069/07-Mum & E/CO-191/07-Mum
(Arising out of Order-in- Original No.20/KKS/06-07 dtd. 21/05/2007 passed by the Commissioner of Central Excise , Mumbai.III )
For approval and signature:
Honble Mr S.S.Kang, Vice President
Honble Mr.Sahab Singh, Member(Technical)
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1. Whether Press Reporters may be allowed to see : No
the Order for publication as per Rule 27 of the
CESTAT (Procedure) Rules, 1982?
2. Whether it should be released under Rule 27 of the :
CESTAT (Procedure) Rules, 1982 for publication
in any authoritative report or not?
3. Whether Their Lordships wish to see the fair copy : seen
of the Order?
4. Whether Order is to be circulated to the Departmental : Yes
authorities?
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M/s. Raymond Ltd.
:
Appellants
VS
Commissioner of Central Excise, Mumbai.III
Respondent
Appearance
Shri P.Shah advocate with Shri V.Sridharan, advocate for Appellants
Shri R.K.Mahajan,Jt.CDR for Respondent
CORAM:
Mr. S. S. Kang, Vice President
Mr.Sahab Singh, Member(Technical)
Date of hearing: 08/09/2011
Date of decision 19/10/2011
ORDER NO.
Per : Sahab Singh
This is an appeal filed by M/s. Raymond Ltd. ( hereinafter referred to as the appellants) against the order passed by the Commissioner of Central Excise, Mumbai.III.
2. The brief facts of the case are that the appellants are the manufacturers of excisable goods falling under Chapter 51, 52, 53, 58, 59 & 62 of CETA, 1985. The appellants were availing exemption for captive consumption under Notification No.67/95-CE dated 16.3.95 for their intermediate products tops, yarn and grey fabrics and were paying duty on their various finished products till 8.7.2004. After the budget of 2004-05, the appellants opted for exemption for their final products as well as intermediate products vide Notification No.30/04 dated 9.7.04 without availing the input stage credit. As per the Board circular No. 795/28/2004-CX dated 28.7.04, the appellants had reversed the cenvat credit availed on the purchased input lying in stock and contained in the Work in progress (WIP) stock and finished stock as on 9.7.04 and started to avail full exemption on the pre-budgetary stock and finished products/WIP stock/input stock as on 9.7.04. As the pre-budgetary stock of finished fabrics/WIP stock/input stock as on 9.7.04 was exempted from central excise duty under Notification No.30/04 dated 9.7.04 , the department took the view that the exemption availed by the assessee under Notfn.No.67/95 in respect of tops, yarn and grey fabrics manufactured by them and used/contained in the finished fabrics stock/WIP (which is now exempted under Notfn.No.30/04) is not available to them for captive consumption because the condition of the Notfn. No.67/95 requires the final goods to be dutiable for availing the exemption under this Notification. Accordingly, a show-cause notice dated 6.7.05 was issued to the appellants demanding duty on
(i) grey fabrics captively consumed upto 8.7.04 and contained in the finished fabric stock of 19,93,515.10 mtrs as on 9.7.04;
(ii) yarn captively consumed upto 8.7.04 and contained in the grey fabric stock of 5,05,014 mtrs as on 9.7.04 and
(iii) tops captively consumed upto 8.7.04 and contained in the yarn WIP stock of 1,75,757 kgs as on 9.7.04.
Penalty under Sec.11AC of CET, 1944 and charging of interest under Sec.11AB of the Act was also proposed in the show-cause notice. The show-cause notice was contested by the appellants and it was adjudicated by the Commissioner vide the impugned order who has confirmed the duty amounting to Rs. 2,15,50,879/- under Sec.11A of the Act alongwith interest under Sec.11AB and a penalty of equal amount of duty was also imposed under Sec.11AC of the Act. Against the impugned order, the appellants have filed this appeal which is before us.
3. The ld.counsel appearing for the appellants submitted that the order passed by the Commissioner is ex facie untenable and unsustainable in law. He submitted that the demand of duty to the extent of duty paid on tops, yarn and grey fabrics contained in stock of yarn in WIP, grey fabrics in WIP and finished fabric lying as such on 9.7.04 cannot be made as the reversal of credit availed thereon amounts to proper discharge of duty. He further submitted that when the appellants manufactured tops, yarn and grey fabrics and availed exemption under Notfn. No.67/95 dated 16.3.95 the final product ie. processed fabrics was dutiable and in view thereof at the time when the appellants consumed the tops, yarn and grey fabrics within the factory of production the exemption claimed by the appellants was correct. He further argued that it is a settled position that duty becomes payable on manufactured product once it is removed from the place of manufacture for consumption and in terms of Rule 5 of CER, 2002, if any excisable goods are used within the factory, the date of removal of such goods shall mean the date on which the goods are issued for such use. Therefore, the date of removal of tops, yarn and grey fabrics manufactured by the appellants were exempted under the Notfn.No.67/95 by reason of the fact that the final product of the appellants was liable to duty at the time of removal of the goods. He relied on the decision of the Supreme Court in the case of Collector of Central Excise, Bombay vs. Kohinoor Mills reported in 1995 (77) ELT 12. In view of the ratio of the decision, he submitted that there is no short payment of duty on the date of removal of the tops, yarn and grey fabrics for use or used in the consumption within the factory.
4. The ld.counsel further contended that provisions of Sec.11A are not applicable in this situation where assessment was correctly made and duty is sought to be demanded by reason of change in law at a later stage or by reason of alleged violation of the condition of the Notification and therefore, show-cause notice issued under the present situation is entirely without jurisdiction. He further submitted that without admitting that provisions of Sec.11A are applicable in the present case, the demand is clearly hit by time limitation as the show-cause notice is issued on 6.7.2005 whereas the relevant date in the present case would be the date on which the intermediate goods were used in the manufacture and that is admittedly much prior to 9.7.2004. He further submitted that in any event no penalty can be imposed on them and no case of demand of interest also.
5. The ld.counsel further submitted that after the issuance of Notfn.No.30/04 the intermediate products manufactured by them also stand exempted under this Notification as they have already reversed the cenvat credit availed by them on the inputs used in the manufacture of final product. He relied upon the judgment of the Gujarat High Court in the case of Commissioner vs. Ashima Dyecot Ltd reported in 2008(232) ELT 580 (Guj) wherein it was held by the Gujarat High Court that once the credit availed was reversed by the assessee, it would amount to as if same was not availed. Therefore, after reversal of the cenvat credit availed, they are not covered under the exclusion proviso to the Notfn.No 30/04 and they become entitled to the exemption under Notfn.30/04. He, therefore, submitted that the demand confirmed by the Commissioner is bad in law and be set aside.
6. Ld. Jt.CDR appearing for the Revenue submitted that Notfn. No. 67/95 clearly states that the intermediate products are exempted from payment of excise duty only if the finished products are not exempted. Since after the issue of Notfn. No.30/04 the finished products became exempted, the benefit of Notfn.No.67/95 is not applicable to them. The exemption under Notfn.No.67/95 is applicable if the intermediate products are used in the manufacture of dutiable finished products. Since in the instant case, tops, yarn and grey fabrics contained in WIP stock and the finished goods were not used in the manufacture of dutiable goods, the exemption is not applicable to them and the Commissioner has correctly demanded the duty from them. Regarding the applicability of Notfn.No.30/04, the ld. Jt.CDR submitted that the proviso to the Notification states that nothing contained in the Notification shall apply to the goods in respect of which credit of duty on inputs or capital goods has been availed by them. He submitted that once the credit has been availed by them, the subsequent reversal of the same would not make the inputs as duty paid in view of the CESTAT decision in the case of Cheviot Company Ltd. vs. CCE, Kolkata reported in 2010(255)E.L.T. 139(Tri-Kolkata) He also relied upon the decision of the Supreme Court in the case of Amrit Paper vs CCE, Ludhiana reported in 2008(12)S.T.R. 536(S.C.) wherein it was held that the assessee who availed the credit at the time of clearance of the goods is not entitled to exemption on reversal of the credit after certain time. Regarding the issue of time limitation, Ld.JCDR submitted that the appellants were required to furnish the quantity and value of the tops, yarn and grey fabrics captively consumed upto July, 2004 by the Range Supdt. vide his letters dated 21.3.05, 18.4.05 & 3.6.05 and the appellants vide their letter dated 23.6.05 informed the Range Supdt. their inability to immediately compute and furnish the quantity and value of tops, yarn and grey fabrics captively consumed without payment of duty under Notfn.No.67/95. They also informed the Range officer that this exercise would be very voluminous and may take 8 to 10 months. In the absence of data furnished by the appellants, the data was derived from the monthly returns submitted by the appellants for the period from January 2004 to June 2004 on pro-rata basis considering the quantity and value of the tops, yarn and grey fabrics captively consumed during the said period. Therefore, the contention of the appellants that show-cause notice is time barred is not tenable as they themselves did not provide the data in time. He further submitted that since the provisions of Sec.11A are correctly applied by the adjudicating authority, imposition of penalty and demand of interest is perfectly in order. Ld. JCDR submitted various case laws on interpretation of Notification, time limitation and imposition of penalty to support his case. He, therefore, requested that the Order-in-Original passed by the Commissioner needs to be upheld.
7. After hearing both sides, we find that the issue involved in the present appeal is, whether the appellants are entitled to exemption on the intermediate product under Notfn.No.67/95 dated 16.3.95 or alternatively under Notfn.No.30/04 dated 9.7.04. Notfn.No.67/95 dated 16.3.95 as amended reads as under:-
In exercise of the powers conferred by sub-section (1) of [section 5A of the Central Excise Act, 1944 (1 of 1944), read with sub-section (3) of section 3 of the Additional Duties of Excise (Goods of Special Importance) Act, 1957 (58 of 1957), (hereinafter referred to as the said Special Importance Act),] the Central Government, being satisfied that it is necessary in the public interest so to do, hereby exempts
(i) capital goods as defined in the CENVAT Credit Rules, 2002, manufactured in a factory and used within the factory of production;
(ii) goods specified in column (1) of the Table hereto annexed (hereinafter referred to as input) manufactured in a factory and used within the factory of production in or in relation to the manufacture of final products specified in column (2) of the said Table;
[from the whole of the duty of excise leviable thereon which is specified in the Schedules to the Central Excise Tariff Act, 1985 (5 of 1986) or additional duty of excise leviable thereon, which is specified in the Schedule to the said Special Importance Act:] Provided that nothing contained in this notification shall apply to inputs used in or in relation to the manufacture of final products which are exempt from the whole of the [duty of excise or additional duty of excise leviable thereon] or are chargeable to nil rate of duty.
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From the Notification it is clear that inputs manufactured in the factory and used within the factory in or in relation to the manufacture of final products are exempt from whole of the duty of excise provided the final products manufactured in the factory are not chargeable to Nil rate of duty. Proviso to the Notification clearly states that this Notification shall not be applicable to the inputs used in the manufacture of final products which are exempt from whole of the duty of excise. In the present case, on 9.7.04, the finished goods were exempted under Notification 30/04 as the appellants have opted for this Notification. The department is demanding duty on the inputs on the ground that the final products become exempted from 9.7.04. Therefore, the inputs contained in tops, yarn and grey fabrics and finished fabrics are chargeable to duty as condition of Notification No.67/95 gets violated. The scheme of the Notification No.67/95 suggests that the duty is payable either on the input stage or on the final product stage. If the final products are exempted, the duty is payable on inputs. If final products are dutiable, the duty is exempted on the inputs. After the issue of Notification No.30/04, the Notification No.67/95 continued to exist and it was not withdrawn.
8. The ld.counsel appearing for the appellants relied upon the decision of the Supreme Court in the case of Collector of Central Excise, Bombay vs Kohinoor Mills (supra) and claimed that since the tops, yarn and grey fabrics are removed from the place of factory, duty is not demandable from them in view of the cited case. We find that in this case, cellulosic spun yarn and cotton yarn were exempted from whole of the duty if yarn for weaving of the cotton fabrics in the factory under the Notification 132/77 which reads as under:-
In exercise of the powers conferred by sub-rule 91) of Rule 8 of the Central Excise Rules, 1944, the Central Government hereby exempts cellulosic spun yarn and cotton yarn falling under sub-item III(i) of Item No.18 and Item No. 18A(i) respectively, of the First Schedule to the Central Excises and Salt Act, 1944 (1 of 1944), when used for weaving of cotton fabrics falling under Item No. 19 in a composite mill, free from whole of the duty of excise leviable thereon:
Provided that when such yarn is produced in a factory other than such composite mill, the procedure set out in Rule 96E of the Central Excise Rules, 1944 is followed.
Explanation. For the purposes of this notification composite mill means a manufacturer who is engaged in spinning of cotton yarn or weaving of cotton fabrics of processing of cotton fabrics with the aid of power and has a proprietary interest in at least two of such manufacturing activities.
And there was also in operation another Notification 131/77 which granted a partial exemption from excise duty to the cotton yarn but because of the Notification No.132/77 such yarn captively consumed was exempted from whole of the duty. This exemption was partially withdrawn by another Notification No.226/77 dated 15.7.1977 under which different rate of duty was prescribed for the cotton fabrics. There was a proviso to the Notification dated 15.7.77 which reads as under:-
Provided further that in cases where cotton fabrics have been produced in a composite mill or are produced therein and in the production of such cotton fabrics cellulosic spun yarn falling under sub-item III (i) of item No. 18 of the said First Schedule or cotton yarn falling under item No. 18A(i) of the said First Schedule, or both, on which no duty of excise was paid prior to the 15th day of July, 1977, was or is used, the duty payable on such fabrics shall be
(a) at the appropriate rate of duty as specified in this notification plus
(b) the duty payable on such cellulosic spun yarn or cotton yarn or both, as the case may be, under the notification of the Government of India in the Department of Revenue and Banking No. 131/77-Central Excise, dated the 18th June, 1977.
It was held by the Supreme Court in this case that the yarn manufactured on or before 18.6.77 and was utilized in the spinning department prior to 15.7.77 , liability to excise duty on such yarn, therefore has to be decided prior to 15.7.77 and since at the relevant time Notification No.132/77 dated 18.6.77 was holding the field under which yarn was wholly exempted from duty, no excise duty was to be paid thereon. We find that in this case, cotton yarn and cellulose yarn was exempt if used captively in the composite mill in the manufacture of cotton fabrics. There were no ineligibility condition in the Notification No.132/77 that the cotton fabrics if exempted from duty, exemption will not be applicable to yarn if captively consumed. Whereas in the present case, there is ineligibility condition in Notification No.67/95 which clearly states that exemption is not applicable if the final products are exempted and this Notification continued to hold the field even after the issuance of Notification No.30/04. In the present case, final products are exempted at the time of removal as appellants themselves opted for availing the Notification No. 30/04. We, therefore, are of the view that the ratio of the cited decision will not be applicable to the facts and circumstances of the present case.
9. The appellants further contended that they are covered by the Notification No.30/04 and claimed that their inputs also stand exempted under this Notification: The Notification No.30/2004 dated 9.7.04 is reproduced below:-
In exercise of the powers conferred by sub-section (1) of section 5A of the Central Excise Act, 1944 (1 of 1944) read with sub-section (3) of section 3 of the Additional Duties of Excise (Goods of Special Importance) Act, 1957 (58 of 1957) and in supersession of the notification of the Government of India in the Ministry of Finance (Department of Revenue) No.7/2003-Central Excise dated the 1st March 2003, published in the Gazette of India vide number of G.S.R 137 (E), dated 1st March 2003, the Central Government, being satisfied that it is necessary in the public interest so to do, hereby exempts the excisable goods of the description specified in column (3) of the Table below and falling within the Chapter, heading No. or sub-heading No. of the First Schedule to the Central Excise Tariff Act, 1985 (5 of 1986) (hereinafter referred to as the Central Excise Tariff Act), specified in the corresponding entry in column (2) of the said Table, from whole of the duty of excise leviable thereon under the said Central Excise Act :
Provided that nothing contained in this notification shall apply to the goods in respect of which credit of duty on inputs or capital goods has been taken under the provisions of the CENVAT Credit Rules, 2002. In this Notification goods mentioned in Col.2 of the Table are exempt from whole of the duty of excise. Under the proviso to the Notification, it is stated that this exemption is not applicable to the goods in respect of which credit of duty on inputs or capital goods has been taken under the provisions of the Cenvat Credit Rules, 2002. Proviso to Notification presupposes that inputs used in the manufacture of final product should be duty paid. It is the submissions of the appellants that cenvat credit taken by them on the inputs procured from outside has already been reversed. Therefore, they should be allowed to avail this exemption on inputs. The Revenue on the other hand relied on Tribunals decision in Cheviot Company Ltd. vs. CCE, Kolkata reported in 2010(255)E.L.T. 139(Tri-Kol) in their favour which held that once the credit has been availed even though it is reversed subsequently, the exemption under Notification No.30/04 should not be applied. The ld. JCDR submitted that Tribunal has referred to CCE vs Ashmia Dyecot Ltd. in this decision. On the other hand, the appellants relied on the judgement of the Gujarat High Court in the case of Commissioner vs. Ashima Dyecot Ltd. 2008(232)ELT 580(Guj) holding that once the credit availed has been reversed it would amount to as if credit not availed.
10. The facts before the High Court in this case were whether the benefit of Notification No. 29/04-CE and 30/04-C E is applicable to the respondents if separate books of accounts are not maintained by the assessee . In this case the assessee is engaged in the manufacture of cotton fabrics falling under Chapter 52 of the Central Excise Tariff Act, 1985. The assessee uses grey cotton, dyes, chemicals, packing material as inputs for manufacture of cotton fabrics and is availing benefit of Notification No.29/04 and 30/04 both dated 9.7.04. Under the Notification No.29/04 the goods were liable to concessional rate of duty whereas under the Notification No.30/04 the goods were wholly exempted from duty provided no credit of duty on inputs has been taken. The Board vide Circular No.795/28/04-CX. dated 28.7.04 had clarified that there is no restriction of availing both benefits simultaneously under the said two Notifications. However, the essential condition for availing the benefit in the said Notifications simultaneously is that the manufacturer should maintain separate books of accounts for goods availing of Notification No.29/04 dated 9.7.04 and for goods availing of Notification 30/04 dtd 9.7.04. The Honble High Court in para 5 of the order has observed as under:-
The Commissioner of Central Excise has decided the matter against the assessee only on the ground that manufacrurer had not maintained separate books of accounts for the goods availing of the benefit of Notification No. 29 of 2004 and for the goods availing of the benefit of Notification No. 30 of 2004. He has further observed that the circular does not speak of final goods or inputs, but, it refers to the goods only and then, he came to the conclusion that as the subjected two notifications refer to the aspect of credit being taken or otherwise of inputs, maintenance of separate accounts for inputs is of prime importance. Since this condition was not satisfied, he confirmed the levy of duty, penalty etc. This finding of the learned Commissioner of Central Excise is not in consonance with the observations made and the ratio laid down by the Honourable Supreme Court in the case of Chandrapur Magnet Wires(P) Ltd. (supra). In para 6 of the order, the High Court observed that the ratio laid down by the Supreme Court in the case of Chandrapur Magnet Wires (P) Ltd. is squarely applicable to the facts of the present case and maintenance of separate books of accounts at the initial stage cannot be considered to be a condition precedent for the purpose of claiming the benefit of exemption Notification.
11. We find that in the case before us, there was no issue of maintenance of separate books of accounts before the original authority.
12. The department on the other hand relies on the decision of the Tribunal in the case of Cheviot Co.Ltd. (supra). The facts in that case were that the appellants were manufacturer of jute yarn and jute Hessian/sacking bags. They were procuring the inputs which have suffered basic excise duty, additional excise duty and education cess. The appellants did not take any credit of BED and AED paid on the inputs. However, they took Cenvat credit of education cess paid on inputs. While clearing the final products, they availed the benefit of exemption notification No.30/04 dated 9.7.04. The said Notification is subject to the condition that nothing contained in this Notification shall apply to the goods in respect of which credit of duty on inputs has been taken under the provisions of the Cenvat Credit Rules, 2002. During the course of audit, it was pointed out to the appellants that inasmuch as they have taken credit amounting to Rs. 1,93,715/- they have not fulfilled the conditions of the Notification No.30/04. The appellants though did not agree with the views of the audit, paid the disputed amount alongwith interest. A show-cause notice was issued to the appellants proposing to deny the benefit under Notification No.30/04. The show-cause notice was confirmed which resulted in an appeal before the Honble Tribunal. In para 6 of the order the Tribunal has observed as under:-
The decision of the Honble Supreme Court in the case of Ganesh Metal Processors Industries (cited supra) rendered in the context of Notification No.202/88-C E which contained the proviso to the Notification prescribing a condition to the effect that no credit of duty paid on inputs has been taken under Rule 56A or 57A of the said Rules is relevant to this case. It has been held by the Honble Supreme Court in the said case that the Notification has to be read as a whole and if any of the conditions laid down in a Notification was not fulfilled, the party was not entitled to the benefit of the Notification. In view of the above, we hold that the appellants having taken credit of one of the duties of excise under the Cenvat Credit Rules, has violated the condition of the Notification. Therefore, they are not entitled to the benefit of the Notification and the Tribunal further observed in para 7 as under: -
Regarding the submission that the appellant has paid back the credit taken by them on 26.9.2006 and therefore, they should be deemed to have not availed the Credit at all in the first place, we are unable to agree with the same. We are of the considered opinion that the decision of the Tribunal in the case of Hind Lamps (cited supra) which had taken into account the decisions in the cases of Chandrapur Magnet Wires (P) Ltd. [1996(81)ELT 3 (S.C.)] and Hello Minerals Water Pvt.Ltd. ( cited supra), will be relevant to the facts of the present case. Further, we notice that the decision of the Honble Supreme Court in the case of Chandrapur Magnet (cited supra) related to reversal of the credit prior to the removal of the goods and taking note of the Boards Circular regarding the difficulty faced in maintaining separate accounts in respect of common inputs. The Tribunal in this case has finally held that the benefit under Notification No.30/04 is not applicable to the appellants in that case. We find that the facts of this case are similar to the facts before us in the present appeal.
13. We also find that the Commissioner while adjudicating the case in para 22 of the order has already subtracted the quantity of the stock purchased by appellants from the market on which credit was reversed by the appellants. Therefore, the issue regarding the reversal of the credit availed by them on the inputs purchased by them will not come in the way of the confirmed amount in the demand. As per the show-cause notice, the tops contained in yarn WIP, yarn contained in grey WIP and grey fabrics contained in the finished fabrics stock were held by the Commissioner as 90,194.15 kgs, 61,206.86 kgs. and 17,72,274.50 Mtrs respectively and total duty liability on these three stocks has been calculated by the Commissioner in para 22 of the order as Rs. 5,12,98,680/-. We also find that the Commissioner has also given the benefit of cenvat credit on tops/tow/fibre contained in WIP stock and he has also given benefit of Cenvat Credit on the inputs purchased ie. tops, Tow & fibres contained in stock of finished fabrics and credit of yarn contained in the stock of finished fabrics. Further, credit of consumables used in grey WIP stock, in yarn WIP, in tops WIP is also given by Commissioner. Thus the total credit on inputs/comsumables attributable is Rs. 2,97,47,801.81. This the entire amount of credit has been reduced by the Commissioner from the duty of Rs. 5,12,98,679/- and the Commissioner has worked out the duty payable by the appellants only to Rs. 2,15,50,879/- . Therefore, we are of the view that since the appellants have opted for Notification No.30/04, the benefit of the Notification No.67/95 is not applicable to them on the inputs used in the manufacture of exempted final products. Relying on decision of Tribunal in case of Cheviot Co.Ltd. (supra), we hold that they are not entitled to exemption under Notification 30/2004. We order accordingly.
14. As regards the point of limitation raised by the appellants, we find that the show-cause notice was issued to the appellants on 6.7.05 and the Range Supdt. vide his letters dated 21.3.05, 18.4. 05 and 3.6.05 asked the appellants to furnish the quantity and value of the inputs used captively by them and the appellants were not able to submit this information to the Range Supdt. and in fact the appellants informed the department their inability to compute and furnish the quantity and value of tops, yarn and grey fabrics captively consumed. Therefore, we are of the view that extended period has rightly been invoked in the show-cause notice by the department and since the appellants have failed to supply the quantity and value of the goods, the finding of the Commissioner that intent to evade payment of duty is proved and accordingly, the penalty under Sec.11AC of the Central Excise Act and interest payable under Sec.11AB is also upheld.
15. In view of the above, we dismiss the appeal filed by the appellants.
16. The Cross-objections filed by the department also stand disposed of accordingly.
(Pronounced in court on 19.10.2011) S. S. Kang Vice President Sahab Singh Member(Technical) pv 24