Custom, Excise & Service Tax Tribunal
M/S Phenix Construction Technology vs Commissioner Of C.Ex. & S.Tax on 7 July, 2017
The Customs, Excise & Service Tax Appellate Tribunal West Zonal Bench At Ahmedabad Appeal No.E/11101/2016-DB [Arising out of OIO No.AHM-EXCUS-002-COMMR-4/2015-16, dt.09.03.2016, passed by Commissioner (Appeals), C.Ex. & S.Tax, Ahmedabad] M/s Phenix Construction Technology Appellant Vs Commissioner of C.Ex. & S.Tax, Ahmedabad-II Respondent
Represented by:
For Appellant: Shri J.C. Patel, Advocate For Respondent: Shri Sameer Chitkara, A.R. (Addl. Commissioner) CORAM:
HONBLE DR. D.M. MISRA, MEMBER (JUDICIAL) HONBLE MR. RAJU, MEMBER (TECHNICAL) Date of Hearing: 31.03.2017 Date of Decision:07.07.2017 Order No.A/11363/2017 Per: Dr. D.M. Misra This is an appeal filed against the OIO No.AHM-EXCUS-002-COMMR-4/2015-16, dt.09.03.2016, passed by Commissioner (Appeals), C.Ex. & S.Tax, Ahmedabad.
2. Briefly stated the facts of the case are that the Appellants are engaged in the manufacture of pre-fabricated engineering building materials and steel structures and components thereof falling under Chapter 94 and 73 of Central Excise Tariff Act, 1985. During the relevant period i.e. from 01.09.2012 to 27.09.2013, the Appellants had cleared the manufactured goods viz. structures and parts of structures for initial setting up of solar power plant, claiming exemption from payment of duty under Notification No.15/2010-CE, dt.27.02.2010 as amended by Notification No.26/2012-CE, dt.08.05.2012. Alleging that the goods which were cleared by the appellant do not satisfy the condition of Notification No.15/2010-CE, dt.27.02.2010, the demand notice was issued for recovery of the duty amounting to Rs.15,58,60,384/- and appropriation of duty already paid for this period, and duty paid for the period subsequently i.e. from 28.09.2013 to March 2014 with interest and proposal for penalty. On adjudication, the demand was confirmed with interest and 50% of the duty as penalty under Section 11AC(c) of CEA,1944 read with Rule 25 of Central Excise Rules 2002. Hence, the present appeal.
3. The learned Advocate Shri J.C. Patel for the appellant submits that the Appellant while clearing the steel structures to one M/s Areva Solar India Pvt. Ltd complied with the condition of the notification inasmuch as the clearances were made against proper certificate issued the Ministry of New and Renewable Energy, recommending grant of the said exemption. It is his contention that even in the Central Excise invoices, the goods were described as structures and parts of structures for initial setting up of solar plant, and the details of the parts of the solar plant were mentioned in the respective packing lists annexed to the excise invoices. It is his contention that in the packing slips for the consignee, the details of parts viz. reflector support beams, support post, upper/middle/lower/vertical weldmen cross beams, etc have been mentioned. It is his contention that these structures are used for supporting of solar panels and components required for initial setting up of solar power generation project or facility to which exemption from payment of excise duty allowed under Notification No.15/2010-CE, dt.27.02.2010 as amended.
4. It is his further contention that the learned Commissioner has erred in observing that the supplied structures do not fall under the category of machinery or apparatus and appliances and also not a components. The learned Advocate submitted that the solar power generation project or facility is based on Compact Linear Fresnel Reflector technology, the solar radiation (sun light) is reflected and focused/concentrated by Linear Fresnel Reflector made up of multiple mirrors mounted on the specially designed steel structure, on to Boiler Tubes located in a Linear Receiver supported on towers above the reflector field. It is his contention that thus, the structures which supports and on which the reflector and receiver are mounted, definitely be called as components of such solar power generation project. He has further submitted that without mounting and supporting the reflector and receiver on the steel structures, the solar power generation project/facility cannot come into existence and would be incomplete.
5. Referring to the meaning of the components mentioned in the Show Cause Notice as well as in the impugned order, the learned Advocate submits that in both these places, the components have been described as a consequential element of a system or part or element of larger whole. He has also submitted that in the report of Indian Technology of solar power generation system, the mounting structures are shown as one of the major components of the solar power generation system. He has further submitted that the publication called Material and Component Specifications Linear Fresnel Reflector prepared by the IT Power India, the support structure is mentioned as one of the key components of a linear fresnel reflector.
6. Advancing his arguments further the learned Advocate submitted that in the letter of Ministry of New and Renewable Energy referred to and relied upon in the Show Cause Notice, it speaks of cement and steel required for construction; which cannot be equated and applied to support structures of its reflectors and receivers used as components and the Ministry itself clarifies that the mounting structures are essential part/component of solar thermal power plant. Besides, the linear fresnel reflector based solar system Operation and Maintenance Manual issued by Ministry of New and Renewable Energy, Government of India, at Para 4.2 and 4.3 mentions that the support structures are one of the main components of reflectors and receivers. He has further submitted that the supporting structures have been manufactured in accordance with the specific drawing and design provided by M/s Areva Solar India Pvt. Ltd, which were meant to be used for the reflectors and receivers. In support of his contention, the learned Advocate referred to the following decisions:-
a) Bharat Heavy Electricals Ltd Vs CC Chennai 1999 (108) ELT 448 (Tribual)
b) CCE Calcutta-II Vs Techno Fab Manufacturing Ltd 2003 (158) ELT 515 (Tri-Kol)
c) Hyundai Unitech Electrical Transmission Ltd Vs CCE Nagpur 2005 (187) ELT 313 (Tri-Mumbai)
d) Ganges International P. Ltd Vs CCE Raipur 2014 (308) ELT 106 ((Tri-Del)
e) ATMASCO (P) Ltd Vs CCE Raipur 2016 (334) ELT 122 ((Tri-Del)
7. He has further submitted that the Circular issued by CBEC No.1008/2015/25-CX, dt.20.10.2015 squarely applies to support structures used in solar generation power project/facility. Further, he has submitted that on an identical issue, in similar facts and circumstances, the Commissioner of Central Excise, Hyderabad has held that the support structures are essential parts of solar generation system and accordingly extended the benefit of exemption Notification No.15/2010-CE, dt.27.02.2010. The learned Advocate further submitted that the Larger Bench of this Tribunal recently in the case of Rakhoh Enterprises Vs CCE Pune 2016 (338) ELT 449 (Tri-LB), has held that wind mill doors are eligible to the exemption Notification No.6/2006-CE, dt.01.03.2006 which allows exemption to wind operated electricity generator, its components and parts thereof including rotor wind turbine controller etc, observing that the wind mills doors are parts. Similarly, also anchor rings and load spreading plates are held to be parts of wind mill operated electricity generator.
8. Per contra, the learned Authorised Representative for the Revenue Shri Sameer Chitkara, reiterating the order passed by the learned Commissioner submitted that the supporting structures classified under Chapter 73 of Central Excise Tariff Act, 1985, cannot be called as components, hence admissible to the benefit of Notification No.15/2010-CE, dt.27.02.2010 as amended. He submitted that the Adjudicating authority, after considering the clarification issued by the Board dt.06.08.2012 and analyzing the evidences on record, the applicability of case laws to the facts of the present case, observed that the steel structures cannot be treated as components of the reflector system, linear receiver or solar steam generator. He has concluded that merely because the steel structures are manufactured on the basis of specific drawing or customization, does not mean that the said structures are components of the solar power generating system. In support of his submission, the learned Authorised Representative for the Revenue referred to the judgment of Tribunal in the case of A.C.C. Limited Vs CCE, Raipur 2013 (295) ELT 708 (Tri-Del) and the decision of Authorities for Advancing Rulings, New Delhi In RE: Enercon (India) Ltd 2011 (270) ELT 132 (AAR).
9. Heard both sides and perused the case records.
10. The issue involved in the present case for consideration is: whether the structures and parts of structures manufactured and cleared for initial setting up of solar power plant consisting of reflector, support beam, support post, upper/middle/lower vertical leg weldment, cross beam are eligible to the benefit of Notification No.15/2010-CE, dt.27.02.2010 as amended. Before reverting to the arguments advanced by both sides, it is necessary to reproduce the said notifications.
Notification No.15/2010-Cx., dt.27.02.2010:
In exercise of the powers conferred by sub-section (1) of Section 5A of the Central Excise Act, 1944, (1 of 1944), the Central Government on being satisfied that it is necessary in the public interest so to do, hereby exempts all items of machinery, including prime movers, instruments, apparatus and appliances, control gear and transmission equipment and auxiliary equipment (including those required for testing and quality control) and components, required for initial setting up of a solar power generation project or facility, from the whole of the duty of excise leviable theron which is specified in the First schedule to the Central Excise Tariff Act, 1985 (5 of 1986), subject to the following conditions, namely-
(1) before the clearance of the goods from the factory, the manufacturer produces to the Deputy Commissioner of Central Excise or the Assistant Commissioner of Central Excise, as the case may be, a certificate, from an officer not below the rank of a Deputy Secretary to the Government of India in the Ministry of New and Renewable Energy recommending the grant of this exemption and the said officer certifies that the goods are required for initial setting up of a solar power generation project or facility; and (2) the manufacturer of such goods furnishes an undertaking to the Deputy Commissioner of Central Excise or the Assistant Commissioner of Central Excise, as the case may be, having jurisdiction, to the effect that
(a) the said goods shall be used only in the said project or facility and not for any other use; and
(b) in the event of failure to observe conditions above, the manufacturer shall pay the duty which would have been leviable at the time of clearance of goods, but for this exemption. (F.No.334/1/2010-TRU) (Prashant Kumar) Under Secretary to the Government of India Notification No.26/2012-Central Excise:
G.S.R. (E).- In exercise of the powers by sub-section (1) of Section 5A of the Central Excise Act, 1944 (1 of 1944), the Central Government, on being satisfied that it is necessary in the public interest so to do, hereby makes the following amendments in the notification of the Government of India, in the Ministry of Finance (Department of Revenue), No.15/2010-Central Excise, dt.27th February, 2010, published in the Gazette of India, Extraordinary vide number G.S.R. 117(E), dated the 27th February, 2010, namely:-
In the said Notification, for conditions (1) and (2), the following shall be substituted, namely:-
(1) an officer not below the rank of a Deputy Secretary to the Government of India, in the Ministry of New and Renewable Energy recommends the grant of this exemption, indicating the quantity, description and specification thereof and certifies that the goods are required for initial setting up of a solar power generation project or facility; and (2) the Chief Executive Officer of the project furnishes an undertaking to the Deputy Commissioner of Central Excise or the Assistant Commissioner of Central Excise, as the case may be, having jurisdiction over the factory of the manufacturer, to the effect that
(i) the said goods will be used only in the said project and not for any other use; and
(ii) in the event of non-compliance of sub-clause (i), the Project Developer of such project shall pay the duty which would have been leviable at the time of clearance of goods, but for this exemption. (F.No.334/1/2012-TRU) (Sanjeev Kumar Singh) Under Secretary to the Government of India
11. The items manufactured and cleared by the Appellant for installation of power generation project, satisfied other conditions prescribed under the said notification, are not in dispute. The point of dispute between the Revenue and the Appellant is that the aforesaid items whether could be called as components required for initial setting up of a solar power generation project or facility. On a plain reading of the aforesaid notification, it is clear that all items of machinery are exempted which included prime movers, instruments, apparatus and appliances, control gear and transmission equipments and auxiliary equipments (including those required for testing and quality control) and components. Needless to say that the said notification covers a wide range of items including those mentioned in the inclusive clause, comprising of machinery required for setting up of a solar power generation project or facility.
12. The items in dispute are claimed by the Appellants as components, since these structures are used as support structures holding the reflectors, an essential part of the solar power generation structures/facility. The learned Advocate for the Appellant took us through the relevant literatures relating to the solar generation facility issued by various agencies.
13. In the booklet titled as Linear Fresnel Reflector based Solar System Operation & Maintenance Manual issued by the Ministry of New & Renewable Energy, Government of India, November, 2014 under the subject Operating Principles, the Components are explained as under:-
4.1 Explanation of System Components:
The LFR consists of parallel rows of linearly coupled reflector units, single axis tracking system, and linear cavity receiver at appropriate height above the reflectors, to receive solar radiation reflected and subsequently focused by the reflectors.
Linear Fresnel Reflector system comprises of the following components:-
* Reflectors * Receiver * Tracking System * Process and Instrumentation System 4.2 Reflector Main components of reflector are:
1. Mirror: High reflective mirror is used as the reflector. It reflects sun rays to the receiver.
2. Corrugated Sheet: It is a wavy structure made up of GI or any other equivalent metal. Mirror is pasted on this sheet. It gives a good support to the mirror and also protects reflective paint of mirror from corrosion. In the literature titled as Material and Component Specifications Linear Fresnel Reflector prepared by IT Power India under the Ministry of New & Renewable Energy, December 2015, explaining the key components of a Linear Fresnel Reflector narrates as follows:-
Linear Fresnel Reflector * Collector * Receiver * Support Structure * Tracking System
14. Also, in a letter dt.09.10.2013, issued by Ministry of New & Renewable Energy, New Delhi, while responding to the query raised by Rajasthan Sun Technique Energy Private Limited, addressed it to Commissioner of Central Excise, Ahmedabad-II, opined that the mounting structure forms an essential part/component of the Solar Thermal Power Plant which is required to mount mirrors/reflectors and solar steam generators to concentrate solar energy and thereby subsequently generate system for power generation.
15. The learned Adjudicating authority, on the other hand, referring to the circular issued by the Ministry of Finance, dt.06.08.2012, while clarifying the eligibility of exemption under No.15/2010-CE, dt.27.02.2010 as amended, where under it is mentioned that the exemption under the said notification does not cover cement, steel and admixture required to execute the civil work to construct buildings, storage tanks etc for solar power project and facility, recorded that the present structures since used for the said purpose, not eligible to the benefit of the said notification. He has observed that the steel structures being used for civil work especially barred from exemption under the said notification.
16. We do not find substance in the observations of the learned Commissioner, inasmuch as there is no evidence on record to show that any of these items have been used for execution of civil work to construct buildings, storage tanks etc. On the other hand, the same are used as detailed in the above technical literature, to hold the reflector one of the main parts of the solar power generation system. Also, it is evident from the following photographs submitted by the Ld. Advocate for the Appellant during the course of hearing .
27. The meaning of components and parts has been explained by five Member Bench of this Tribunal in the case of Jindal Strips Ltd Vs Collector of Customs, Bombay 1997 (94) ELT 234 (Tribunal) while drawing distinction between parts & component in the context of exemption Notification No.77/90-Cus., dt.20.03.1990 as:
12.?Part is defined in Blacks Law Dictionary Sixth Edition at page 1117 as under :-
An integral portion, something essential belonging to a larger whole; that which together with another or others makes up a whole ........ a portion, share or purpart.
In Chambers 20th Century Dictionary the meaning given for component is as under:-
one of the parts or elements of which anything is made up, or into which it may be resolved.
In Oxford Dictionary the meaning of component is :-
Contributing the composition of whole In Websters Dictionary the meaning given is A part; a constituent, an ingredient. In our view, the common parlance meaning of the expression component is also the same, that is, one of the parts or elements of which anything is made up or into which it may be resolved or a constituent. The meaning in common parlance has to be looked into since the notification itself does not contain any definition of the expression.
13.?Several decisions of High Courts containing reference to part, component or spares have been placed before us in the course of submissions. In C.S.T. v. Amar Radio Cabinet Works - 1968 (22) STC 63 (Bom. HC) entry No. 65 in the Bombay Sales Tax Act referring to wireless apparatus, radiographs, loudspeakers etc. and spare parts of wireless equipments and radiographs was considered. The question was whether radio cabinets sold by a dealer would attract entry 65 or the residuary entry 22. It was held that while the word part has a general sense, spare part takes colour from the word spare, that is a part which would require replacement in ordinary course on account of wear and tear and would not have the amplitude of the word component. It was indicated that the owner of radio will not ordinarily keep an extra cabinet spare and, therefore, cabinet cannot be regarded as a spare part, though it is a component of radio and, therefore, entry No. 65 would not apply. In Commissioner of Sales Tax v. Pritam Singh - 1968 (22) STC 414 (All. HC) the question arose in the context of manufacture of bodies of motor vehicles. Item 24 of the exemption notification referred to motor vehicles and component parts of motor vehicles. It was held that a component part of an article is an integral part necessary for the constitution of the whole article and without it the article will not be complete and body of a motor vehicle being an integral part of the motor vehicle has to be regarded as a component part. In Sujan Singh & Another v. A.A.C. Sales Tax - 1969 (24) STC 504 (Delhi HC) the question was whether the body of motor vehicle is a spare part within the meaning of the entry motor vehicles including chassis of motor vehicles, motor tyres and tubes and spare parts of motor vehicles under item 1 of first schedule to the Bengal Finance (Sales Tax) Act. It was held that spare part is an extra part kept for use in emergency for replacement, that every component will not be a spare part and no owner of vehicle would keep a body of motor vehicle as spare part and, therefore, it cannot be regarded as a spare part. In Bajoria Halwasiya Service Stn. v. The State of Uttar Pradesh - 1970 (26) STC 108 (All. HC) a similar question arose under the provisions of the U.P. Sales Tax Act and a notification issued thereunder. It was held that body of a motor vehicle is not a spare part, though it is a component since a spare part means a part kept in readiness for use in emergency and no owner of vehicle will keep body of a vehicle in readiness for use in emergency. It was held that every component part need not be a spare part while every spare part will necessarily be a component part.
14.?In Paul Lazar v. State of Kerala - 1977(40) STC 437 (Kerala HC) it was held that copper wire used in manufacture of transformers is not a component part thereof. It was indicated that component part has to be an identifiable object and copper wire used in the manufacture of transformer is not an identifiable object.
15.?In Ghaziabad Engg. Co. (P) Ltd. v. Commr. of Sales Tax - 1991 (80) STC 243 (Delhi HC) under the provisions of the Bengal Finance (Sales Tax) Act, the court considered entry 1 of first schedule of Bengal Finance (Sales Tax) Act, namely, motor vehicles, including motor vehicles tyres and tubes and spare parts of motor vehicles and held that fuel injection pump, which is a part of diesel engine is a component part of the diesel engine and not a component part of the motor vehicle and, therefore, the fuel injection pump sold as a spare part would not be a spare part of motor vehicle. In Khoday Distilleries (P) Ltd v. Commr. of Commercial Taxes, Karnataka - 1991 (82) STC 251 (Karnataka HC) it was held that molasses used in the manufacture of Ethyl alcohol can be identified by chemical test and, therefore, is a component part of the end product. The Supreme Court in State of Madras v. R.M.K. Krishnaswami Naidu and Others - 1970 (26) STC page 42 has taken a similar view. In State of Tamil Nadu v. Tube Investments of India Ltd. - 1992 (85) STC 245 (Madras HC) it was held that dynamo of a cycle is not a component part but an accessory of cycle. In Televista Electronics v. Commr. of Sales Tax - 1992 (87) STC 410 (Delhi HC) in considering the entry relating to wireless receiving instruments and spare parts and accessories in the schedule to the Bengal Finance (Sales Tax) Act, it was held that a spare part is always a component part but the converse may not be invariably true.
15.?In Star Paper Mills Ltd. v. Collector of Central Excise - 1989 (43) E.L.T. 178 (S.C.), the Supreme Court held that paper core used for rewinding of paper in rolls is a component part within the meaning of Notification No. 201/79. The court relied on the dictionary meaning of the word component as a constituent part. Since use of paper core is necessary for rewinding of paper if delivered to the customers in rolls, it should be a component part within the meaning of the Notification.
16.?Notifications 246/76, 77/90 and 112/87 do not define the word component part with the result that one has to go by the meaning the word carries in common parlance. The dictionary meaning of component is one of the parts or elements of which anything is made of or into which it may be resolved, or a constituent part and this meaning has been accepted by the Supreme Court in Star Paper Mills Ltd. - 1989 (43) E.L.T. 178. Much is sought to be made out of the meaning stated as constituent part . The suggestion is that it must be a part in the initial constitution of the manufactured product. This suggestion is merely based on a priori assumption. Constituent, according to Chambers 20th Century Dictionary means :-
constituting or forming; essential; elemental; component; electing; constitution-making - n. an essential or elemental part; one of those who elect a representative, esp. in parliament; an inhabitant of ones constituency. Thus, constituent only means an essential part or component. Use of the words component parts or constituent parts is an example of tautology. Constituent and component essentially mean the same thing, that is, an essential part of which anything is made of or into which it may be resolved. When parts are put together to create an end product, they are regarded as component parts. When an assembled product is dismantled, it gives rise to component parts. Whatever be the stage, that is, before assembling, after assembling and after dismantling, such essential are [integral] part is a component, when a component part is damaged or is worn out and therefore requires replacement and is replaced, the replacing part does not cease to be a component part because it was not present in the initial assembly and had been put in the place of a damaged or worn out component part. The much wider meaning given to the expression component in Khodey Distilleries (P) Ltd. v. Commissioner of Commercial Taxes, Karnataka and Others - 1991 (82) STC 251 (Kar. HC) and in State of Madras v. R.M.K. Krishnaswami Naidu & Ors. - 1970 (26) STC 42 (SC) does not affect this position. A spare is a replacement part, to replace a damaged or worn out component; nevertheless it is a component part.
17.?Component is the genus and spare is a species that is, component which is used for replacement. If all that is available is the use of the expression component or component part, the usage must be understood in its normal connotation, in the absence of any specific qualification or restriction. There are several notifications where such qualifying or restrictive words have been used to suggest that the component part must have been used in the initial assembly or in the manufacture of the final product thereby excluding spare from the ambit of the expression component part. There are no such qualifying or restrictive words used in the notifications under consideration. Hence, with respect, it is not possible to agree with the view taken in some of the decisions of the Tribunal that component implies parts used in the initial assembly or manufacture and excludes spares. The amplitude and significance of the word component cannot be cut down in the absence of clear words indicative of any intention to restrict its meaning and operation. The view taken in Vaz Fowarding Pvt. Ltd. - 1989 (43) E.L.T. 358 (Tribunal) was not followed in Metal Impacts Pvt. Ltd. - 1993 (64) E.L.T. 286 (Tribunal), but the distinction drawn based on the fact that the words component parts occur in isolation and not in conjunction with the final product is a distinction without difference. The amplitude of the words component part is not in any way restricted by using the words in conjunction with the article of which they are component parts.
28. The aforesaid decision of the Tribunal was later upheld by Hon'ble Supreme Court in the case of Hindustan Sanitaryware & Industries Ltd Vs. Collector of Customs, Calcutta 1999 (114) ELT 778 (SC).
29. The Tribunal in the case of Ganges International Pvt. Ltd. Vs CCE Raipur 2014 (308) ELT 106 ((Tri-Del), while considering the goods viz. General Fabrication Structures, Auto Welded Beams and Boxes for Thermal Power Project, in the context of its eligibility to exemption under Notification No.6/2006-CE, dt.1.3.2006, mentioned at Sr.No.13 of the table annexed to the Notification, has observed as follows:-
7. In our view, even if the General Fabrication Structures, Auto Welded Beams and Boxes cleared by the appellant are meant to be used as Supporting Structure for some machinery, the same would have to be treated as component parts of that machinery as the description of goods against Sl. No. 91B of Notification No. 6/2006-C.E., Sl. No. 338 of Notification No. 12/2012-C.E. covers all components whether finished or not and raw materials for the manufacture of the items of machinery, prime movers, instruments, apparatus, appliances, control gear, transmission equipments etc. In view of this, the impugned order denying exemption to the goods supplied to Prayagraj Super Thermal Mega Power Project is also not sustainable.
30. Also, we find that recently the Larger Bench of the Tribunal in the case of Rakhoh Enterprises (supra), while considering the eligibility of the items viz. doors of windmills under the exemption under Notification No.6/2006-CE as amended observed that these are parts of Wind Operated Electricity Generator (WOEG) and eligible to the benefit of notification. Similar findings are also recorded in the case of items viz. anchor rings and load spreading plates as parts of the tower specifically designed for wind operated electricity generator and accordingly eligible to Notification No.6/2006-CE, dt.01.03.2006.
31. Therefore, considering the meaning of component elucidated in the aforesaid judgments, the technical literatures and other evidences produced by the Appellant , we find merit in the contention of the learned Advocate for the Appellant that the items in question definitely be considered as components of the reflector, undisputedly used being required for initial setting up of a solar power generation project or facility, hence eligible to the benefit of exemption Notification No.15/2002CE dt.27.02.20010, as amended.
32. In the result, the impugned Order is set aside and the Appeal is allowed with consequential relief, if any, as per law.
(Pronounced in the court on 07.07.2017)
(Raju) (Dr. D.M. Misra)
Member (Technical) Member (Judicial)
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