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[Cites 8, Cited by 0]

Custom, Excise & Service Tax Tribunal

M/S. Hindustan Unilever Ltd. vs Commissioner C Ex- Dibrugarh on 22 September, 2023

IN THE CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL,
                         KOLKATA

                       REGIONAL BENCH - COURT NO.1

                     (1)    Excise Appeal No.197 of 2010
                               (On behalf of Appellant)

 (Arising out of Order-in-Original No.01/SPECIAL RATE/CE/DIB/2009 dated
22.09.2009 passed by the Commissioner of Central Excise & Service Tax, Dibrugarh)

M/s Hindustan Unilever Limited
(Personal Products Factory, Unit I, Doomdooma Industrial Estate, District-Tinsukia,
Pin-786151)
                                                                          Appellant
                                   VERSUS

Commissioner of Central Excise & Service Tax, Dibrugarh
Milan Nagar, Lane "F", P.O.-C.R.Building, Dibrugarh-786003
                                                                Respondent


                                       WITH

   (2)    Excise Appeal No.198/2010

          (M/s Hindustan Unilever Limited Vs. Commissioner of Central
          Excise & Service Tax, Dibrugarh)

Arising out of Order-in-Original No.02/SPECIAL RATE/CE/DIB/2009 dated 22.09.2009
passed by the Commissioner of Central Excise & Service Tax, Dibrugarh)

   (3)    Excise Appeal No.477/2012

          (M/s Hindustan Unilever Limited Vs. Commissioner of Central
          Excise & Service Tax, Dibrugarh)

Arising out of Order-in-Original No.01/TECH/2012 dated 24.04.2012 passed by the
Commissioner of Central Excise & Service Tax, Dibrugarh)

   (4)    Excise Appeal No.478/2012

          (M/s Hindustan Unilever Limited Vs. Commissioner of Central
          Excise & Service Tax, Dibrugarh)

Arising out of Order-in-Original No.02/TECH/2012 dated 24.04.2012 passed by the
Commissioner of Central Excise & Service Tax, Dibrugarh)

   (5)    Excise Appeal No.71266/2013

          (M/s Hindustan Unilever Limited Vs. Commissioner of Central
          Excise & Service Tax, Dibrugarh)

Arising out of Order-in-Original No.02/TECH/2013 dated 17.07.2013 passed by the
Commissioner of Central Excise & Service Tax, Dibrugarh)
                                         2


                        Excise Appeal Nos.197,198/2010, 477,478/2012,
                                71266,71267/2013, 75637-75639/2014,
                              76131,76132/2014, 75765-75770/2016 &
                                                   77120-77122/2017




   (6)    Excise Appeal No.71267/2013

          (M/s Hindustan Unilever Limited Vs. Commissioner of Central
          Excise & Service Tax, Dibrugarh)

Arising out of Order-in-Original No.03/TECH/2013 dated 17.07.2013 passed by the
Commissioner of Central Excise & Service Tax, Dibrugarh)

   (7)    Excise Appeal No.75637/2014

          (M/s Hindustan Unilever Limited Vs. Commissioner of Central
          Excise & Service Tax, Dibrugarh)

Arising out of Order-in-Original No.05/TECH/2013-14 dated 05.02.2014 passed by the
Commissioner of Central Excise & Service Tax, Dibrugarh)

   (8)    Excise Appeal No.75638/2014

          (M/s Hindustan Unilever Limited Vs. Commissioner of Central
          Excise & Service Tax, Dibrugarh)

Arising out of Order-in-Original No.06/TECH/2013-14 dated 07.02.2014 passed by the
Commissioner of Central Excise & Service Tax, Dibrugarh)

   (9)    Excise Appeal No.75639/2010

          (M/s Hindustan Unilever Limited Vs. Commissioner of Central
          Excise & Service Tax, Dibrugarh)

Arising out of Order-in-Original No.07/TECH/2013-14 dated 07.02.2014 passed by the
Commissioner of Central Excise & Service Tax, Dibrugarh)

   (10) Excise Appeal No.76131/2014

          (M/s Hindustan Unilever Limited Vs. Commissioner of Central
          Excise & Service Tax, Dibrugarh)

Arising out of Order-in-Original No.01/DIB/TECH/2014-15 dated 29.04.2014 passed
by the Commissioner of Central Excise & Service Tax, Dibrugarh)

   (11) Excise Appeal No.76132/2014

          (M/s Hindustan Unilever Limited Vs. Commissioner of Central
          Excise & Service Tax, Dibrugarh)

Arising out of Order-in-Original No.02/DIB/TECH/2014-15 dated 29.04.2014 passed
by the Commissioner of Central Excise & Service Tax, Dibrugarh)

   (12) Excise Appeal No.75765/2016

          (M/s Hindustan Unilever Limited Vs. Commissioner of Central
          Excise & Service Tax, Dibrugarh)
                                       3


                       Excise Appeal Nos.197,198/2010, 477,478/2012,
                               71266,71267/2013, 75637-75639/2014,
                             76131,76132/2014, 75765-75770/2016 &
                                                  77120-77122/2017




Arising out of Order-in-Original No.05-DIB-TECH-2015-16 dated 17.02.2016 passed
by the Commissioner of Central Excise & Service Tax, Dibrugarh)

   (13) Excise Appeal No.75766/2016

         (M/s Hindustan Unilever Limited Vs. Commissioner of Central
         Excise & Service Tax, Dibrugarh)

Arising out of Order-in-Original No.04-DIB-TECH-2015-16 dated 17.02.2016 passed
by the Commissioner of Central Excise & Service Tax, Dibrugarh)

   (14) Excise Appeal No.75767/2016

         (M/s Hindustan Unilever Limited Vs. Commissioner of Central
         Excise & Service Tax, Dibrugarh)

Arising out of Order-in-Original No.06-DIB-TECH-2015-16 dated 17.02.2016 passed
by the Commissioner of Central Excise & Service Tax, Dibrugarh)

   (15) Excise Appeal No.75768/2016

         (M/s Hindustan Unilever Limited Vs. Commissioner of Central
         Excise & Service Tax, Dibrugarh)

Arising out of Order-in-Original No.08-DIB-TECH-2015-16 dated 17.02.2016 passed
by the Commissioner of Central Excise & Service Tax, Dibrugarh)

   (16) Excise Appeal No.75769/2016

         (M/s Hindustan Unilever Limited Vs. Commissioner of Central
         Excise & Service Tax, Dibrugarh)

Arising out of Order-in-Original No.07-DIB-TECH-2015-16 dated 17.02.2016 passed
by the Commissioner of Central Excise & Service Tax, Dibrugarh)

   (17) Excise Appeal No.75770/2016

         (M/s Hindustan Unilever Limited Vs. Commissioner of Central
         Excise & Service Tax, Dibrugarh)

Arising out of Order-in-Original No.03-DIB-TECH-2015-16 dated 17.02.2016 passed
by the Commissioner of Central Excise & Service Tax, Dibrugarh)

   (18) Excise Appeal No.77120/2017

         (M/s Hindustan Unilever Limited Vs. Commissioner of Central
         Excise & Service Tax, Dibrugarh)

Arising out of Order-in-Original No.01-DIB-TECH-2017-18 dated 21.08.2017 passed
by the Commissioner of Central Excise & Service Tax, Dibrugarh)
                                       4


                       Excise Appeal Nos.197,198/2010, 477,478/2012,
                               71266,71267/2013, 75637-75639/2014,
                             76131,76132/2014, 75765-75770/2016 &
                                                  77120-77122/2017




     (19) Excise Appeal No.77121/2017

          (M/s Hindustan Unilever Limited Vs. Commissioner of Central
          Excise & Service Tax, Dibrugarh)

Arising out of Order-in-Original No.07-DIB-TECH-2017-18 dated 21.08.2017 passed
by the Commissioner of Central Excise & Service Tax, Dibrugarh)

     (20) Excise Appeal No.77122/2017

          (M/s Hindustan Unilever Limited Vs. Commissioner of Central
          Excise & Service Tax, Dibrugarh)

Arising out of Order-in-Original No.03-DIB-TECH-2017-18 dated 21.08.2017 passed
by the Commissioner of Central Excise & Service Tax, Dibrugarh)


APPERANCE :

Shri M.H.Patil, Mr.Viraj Reshamwala & Ms.Satabdi Chatterjee, all Advocates for
the Appellant
Shri S.Mukhopadhyay, Authorized Representative for the Respondent

CORAM:
HON'BLE MR.ASHOK JINDAL, MEMBER (JUDICIAL)
HON'BLE MR.K.ANPAZHAKAN, MEMBER (TECHNICAL)

               FINAL ORDER NO...76741-76760/2023


                                             DATE OF HEARING : 23 .08.2023

                                    DATE OF PRONOUNCEMENT : 22.09.2023
Per Ashok Jindal :

       As all the appeals are having a common issue, therefore, all the

appeals filed by the appellants are being disposed off by a common

order.

2.     The facts of the case are that the appellants are engaged in the

manufacture of Oral Preparations, Cosmetics, Hair Care & Skin Care
                                       5


                       Excise Appeal Nos.197,198/2010, 477,478/2012,
                               71266,71267/2013, 75637-75639/2014,
                             76131,76132/2014, 75765-75770/2016 &
                                                  77120-77122/2017



Preparations at their factories at Doomdooma Estate, Dist. Tinsukia,

Assam.

2.1        On 20.11.1997, the Central Government announced an

Industrial Policy, inviting entrepreneurs to set up new industrial Units

in North-Eastern States and promised that such Units would be exempt

from payment of central excise duty and income tax for a period of 10

years from the date of commencement of their commercial production.

The Ministry of Industry notified the Industrial Policy on 24th

December 1997.      In order to aid industrial growth in various non-

developed areas of the country, including north-eastern States, Central

Govt. issued Notifications granting exemption from payment of central

excise duty on the goods manufactured in such areas.

2.2   Accordingly, a Notification No.32/1999-CE dated 08.07.1999 was

issued granting exemption from duty of excise or additional duty of

excise equivalent to the amount paid from PLA, by way of refund of

such duty paid from PLA, after exhausting the Cenvat credit balance.

2.3   In   this   regard,   another   Notification   No.56/2002-CE    and

Notification No. 57/2002 both dated 14.11.2002 for Jammu & Kashmir,

Notn. No. 56/2003-CE dated 10.06.2003 and Notification No.71/2003-

CE dated 09.09.2003 for Sikkim, etc. were issued.

2.3    In order to avail of the benefits under the said Notifications, the

appellants set up the following factories at Doomdooma Industrial

Estate in Tinsukia District of Assam State:
                                         6


                       Excise Appeal Nos.197,198/2010, 477,478/2012,
                               71266,71267/2013, 75637-75639/2014,
                             76131,76132/2014, 75765-75770/2016 &
                                                  77120-77122/2017




         (i)     Unit No.1 in August 2001
         (ii)    Unit No.2 in April 2003
         (iii)   Unit No.3 in March 2013


         The appellants were manufacturing the following goods in their

         Units:



                   Unit No.1     Unit No. 2     Unit No.3
          Sr.                  Name of the products             Chapter
          No.
          1.      Hair Care       Hair Care       Hair Care     33
          2.      Talcum          Talcum Powder   ---           33
                  Powder
          3.      Skin Cream      Skin Cream      Skin Cream 33
          4.      Vaseline        ---             ---           27
                  Petroleum
                  Jelly
          5.      Oral            Oral Care       ---           33
                  Care/
                  Toothpast
                  e




2.4   Notification No.17/2008-CE dated 27.03.2008 was issued, for

amending the Notification Notn.No.32/99-CE dated 08.07.1999, for

providing for exemption of duty payable on value addition, subject to

payment thereof from PLA (after exhausting Cenvat credit). The

exemption from duty payable on value addition or to the extent of duty

actually paid from PLA, whichever is less, was admissible; for which an

application to the Commissioner was to be made within 60 days from

the beginning of the financial year, if the manufacturer finds that four-
                                        7


                        Excise Appeal Nos.197,198/2010, 477,478/2012,
                                71266,71267/2013, 75637-75639/2014,
                              76131,76132/2014, 75765-75770/2016 &
                                                   77120-77122/2017



fifth of the ratio of actual value addition in the production or

manufacture of the goods to the value of the goods, was more than

the rate specified in the amending Notification.

2.5      The said Notification No.32/99-CE was further amended

through Notification No.31/08-CE dated 10.06.2008, providing for

fixation of special rate, if the manufacturer finds that actual value

addition of the goods is more than 115% of the percentage prescribed

in the Notification; for which, an application to the Commissioner was to

be made, not later than 30th September of the respective financial

years.

2.6      The Explanation to Para 2.1(4) of Notification No.32/99-CE

prescribed the following formula to arrive at actual value addition

based on financial records of the preceding financial year, which is as

reproduced below:


               "xxxxx                      xxxxx                     xxxxx
               (iv)     Sale value of the said goods excluding excise
                        duty, Value Added Tax and other indirect taxes, if
                        any, paid on the goods;
               (v)      Less: Cost of raw materials and packing materials
                        consumed in the said goods;
               (vi)     Less: Cost of fuel consumed if eligible for input
                        credit under CENVAT Credit Rules, 2004;
               (vii)    Plus: Value of said goods available as inventory in
                        the unit but not cleared, at the end of the financial
                        year;
               (viii)   Less: Value of said goods available as inventory in
                        the unit but not cleared, at the end of the financial
                                           8


                           Excise Appeal Nos.197,198/2010, 477,478/2012,
                                   71266,71267/2013, 75637-75639/2014,
                                 76131,76132/2014, 75765-75770/2016 &
                                                      77120-77122/2017



                           year preceding that under consideration.
                   xxxxx                       xxxxx                    xxxxx"


2.7         Value addition for all goods falling under Chapter 33 i.e.

"Cosmetics     &   Toilet     Preparations",   being     manufactured    by   the

Appellants, was fixed at 56%, at Sr. No. 3 of the Table under Para 2A of

the Notification No. 32/99-CE, as amended by the said Notifications. In

other words, the Appellants were entitled to exemption/refund of 56%

of the total duty payable on the goods manufactured and cleared by

them, subject to the amount paid from PLA.

2.8         In view of actual value addition to the sales value was more

than 115% of the prescribed percentage of 56% (i.e. 64.4%), the

Appellants made separate applications for Units No. 1, 2, & 3 for each

of the Financial Years from 2008- 09 to 2016-17, supported by

requisite    documents,       including   certificates   from   their   Statutory

Auditors, M/s. Lovelock & Lewes, for the Financial Year 2008- 09 to

2013-14 and M/s. B.S.R & Co LLP, for Financial Years 2014-15 to 2016.

2.9   The said Statutory Auditors issued certificates based on the

audited Balance Sheets and Profit & Loss Accounts for the financial

years 2008-09 to 2016-17. The Appellants, in each of the financial

years, claimed value addition ranging between 62% and 83%, product

wise, as summarized below:
                                          9


                        Excise Appeal Nos.197,198/2010, 477,478/2012,
                                71266,71267/2013, 75637-75639/2014,
                              76131,76132/2014, 75765-75770/2016 &
                                                   77120-77122/2017



Sr.  Name of the    Financial    Value       Percentage      115% of Value
 No.   product        year      addition      of value         addition &
                                 as per       addition        percentage
                                Statutory    specified in     specified in
                                Auditors     Notifications    Notifications


 (1)       (2)         (3)         (4)            (5)             (6)

1.     Hair Care                  74%            56%             64%
2.     Talcum       2008-09       62%            56%             64%
       Powder
3.     Skin Cream                 81%            56%             64%
4.     Oral Care                  69%            56%             64%
5..    Hair Care                  66%            56%             64%
6.     Skin Cream   2009-10       79%            56%             64%
7.     Oral Care                  65%            56%             64%
8.     Hair Care                  70%            56%             64%
9.     Skin Cream   2010-11       83%            56%             64%
10.    Oral Care                  68%            56%             64%
11.    Hair Care                  65%            56%             64%
12.    Skin Cream   2011-12       83%            56%             64%
13.    Vaseline                   56%            36%             41%
       Petroleum
       Jelly
14.    Oral Care                  67%            56%             64%
15.    Hair Care                  67%            56%             64%
16.    Skin Cream               82% / 84%        56%             64%

17.    Vaseline                   66%            36%             41%
       Petroleum
       Jelly        2012-13
18.    Oral Care                  66%            56%             64%
19.    Hair Care                  79%            56%             64%
20.    Hair Care                68% / 75%        56%             64%
21.    Skin Cream               82% / 83%        56%             64%

22.    Vaseline                   66%            36%             41%
       Petroleum    2013-14
       Jelly
                                        10


                          Excise Appeal Nos.197,198/2010, 477,478/2012,
                                  71266,71267/2013, 75637-75639/2014,
                                76131,76132/2014, 75765-75770/2016 &
                                                     77120-77122/2017



23.             Oral Care                     65%           56%                  64%
24.             Hair Care                     67%           56%                  64%
25.             Skin Cream                    83%           56%                  64%
26.             Vaseline        2014-15       69%           36%                  41%
                Petroleum
                Jelly
27.             Oral Care                     67%           56%                  64%
28.             Skin Care                     68%           56%                  64%
29.             Hair Care       2016-17       70%           56%                  64%
30.             Skin Care                     86%           56%                  64%
31.             Vaseline                      78%           36%                  41%
                Petroleum
                Jelly
32.             Oral Care                     67%           56%                  64%


2.10     The Appellants filed separate applications for fixation of

special rate for each Unit financial year-wise for the disputed period,

along with     relevant    documents, including       certificates    issued       by

Statutory Auditors.

2.11     The    aforesaid      applications have     been      rejected     by    the

Commissioners, on the following grounds:

         (a) that the Balance Sheet, based on which the computation
         of value addition has been done by the Appellants, is not in
         conformity with Section 211 of Companies Act, 1956;
         (b) that Section 211 of Companies Act, 1956 does not contain
         any provision to prepare Balance Sheet or financial records for
         the same company, for different purpose;
         (c)    that the gross sales value (GSV) arrived at by the
         Appellants       by   multiplying   the    quantity     of   the    goods
         manufactured and cleared from the Unit with All India
         Average Rate of sales realization at the Depots. The GSV
         represents an amount which relates to goods manufactured
                                       11


                       Excise Appeal Nos.197,198/2010, 477,478/2012,
                               71266,71267/2013, 75637-75639/2014,
                             76131,76132/2014, 75765-75770/2016 &
                                                  77120-77122/2017




         by the number of manufacturing units located at different
         parts of the country and not solely the Units in NESA.
         Therefore, it is incorrect, as the actual cost of production of
         the said Units is not considered;
         (d)       that as per Explanation to Para 4 of Notification
         No.32/99-CE, the computation of value addition does not
         include work-in-progress;

         (e)       that GSV was arrived at by taking All India average
         rate of sales realization of the company and the average rate
         of VAT at the rate of 12.5% has been deducted from the
         gross sales value. This does not show the true picture of
         value    addition    considering    the    fact   that   the     products
         manufactured by the Appellants attract various rates of taxes
         under VAT;
         (f)    that the Appellants have valued the inventory physically
         lying at the Units including the WIP at the cost of raw materials
         and packing material consumed. As per accounting standards,
         the valuation of the inventory has to be made on the basis of
         cost     of   raw    material,     packing,       factory      overheads,
         administrative      overheads,     etc.   Therefore,     the    value   of
         inventory of stock does not represent fair and true value;
         (g)       Some of the applications have been rejected on
         merits and some of the applications have been rejected both
         on merits and time bar.




2.12 Aggrieved from the said orders, the appellants are before us.
                                      12


                      Excise Appeal Nos.197,198/2010, 477,478/2012,
                              71266,71267/2013, 75637-75639/2014,
                            76131,76132/2014, 75765-75770/2016 &
                                                 77120-77122/2017



3.    The Ld.Counsel appearing on behalf of the appellant submits that

the products manufactured at the above mentioned units,                    the

Appellants are delivered to their depots from where the same are sold at

a uniform selling price. The term uniform selling price indicates that

there is uniform all India average rate prevalent at all the depots of the

Appellants and hence, multiplying the number of units cleared from the

unit with the said all India average rate of selling price is the only and

correct way of computing the gross sales value. The fact of actual cost

of product at each unit being considered or relevant in computation of

sales value as elaborated above.          He further submits that different

states have different rates of sales tax. It is not possible for Appellants

who being multi-product, multi-locational company to identify as to

what quantity of which product, stock transferred to         their Depot, is

sold in which state, in order to claim the amount of sales tax against

that particular clearance. In view of this, the Appellants' claim of the

total sales tax paid, on average basis, is computed as under:



         Total sales tax paid
         all over India on a
         particular product,
         --------------------------------------x 100 = Average Sales Tax
         Total sales value of that product, paid in terms of Percentage.


The above would give the actual sales tax payable and paid as

percentage of the sales value. It may be clarified that the total sales

tax paid and that claimed is equal. The only difference is that it has
                                    13


                      Excise Appeal Nos.197,198/2010, 477,478/2012,
                              71266,71267/2013, 75637-75639/2014,
                            76131,76132/2014, 75765-75770/2016 &
                                                 77120-77122/2017



been claimed on equalised basis. Since the Appellants are not claiming

Sales Tax Deduction more than what was paid (i.e. paid to various

States under the name and style sales tax), the same is admissible

deduction, irrespective of whether it is claimed on equalised basis or

otherwise. Claiming of admissible deductions like Sales Tax, etc. on

equalized basis is permissible as has been held by Hon'ble Tribunal and

Supreme Court in Appellants' own following cases:


         (b)   Hindustan Unilever Ltd. - 2016 (334) ELT 95(T)
         (c)   Hindustan Unilever Ltd. - 2016 (341) ELT 434 (T)


In view of the above, the finding in the impugned Order to the effect

that by taking all India average rate of sales tax as well as sales

realization, actual   value addition cannot be arrived at, is not

sustainable.

3.1   He further submits that by resorting to valuation based on

conservative method of valuing inventory at cost of raw materials and

packing materials is correct. In any case, the same method of valuation

has been resorted to for both, opening stock and closing stock. It is

not a case of undervaluing opening stock and overvaluing closing stock

to arrive at higher percentage of valuation addition. Further, for the

period from 2012 to 2017, there are no finished goods inventory. In

2012, automatic conveyor system was installed in the NESA Plant, from

where goods after being manufactured was directly transferred to the
                                      14


                      Excise Appeal Nos.197,198/2010, 477,478/2012,
                              71266,71267/2013, 75637-75639/2014,
                            76131,76132/2014, 75765-75770/2016 &
                                                 77120-77122/2017



godown on real time basis. Hence, no inventory was available in the

factory during this period.

3.2   He further submits that the Commissioner's finding that the

Balance Sheet is not in conformity with the Companies Act, 1956, is

incorrect, based on the following submissions:

         (i)    that a Certificate from Statutory Auditors, containing

         the calculation of value addition based on the audited Balance

         Sheet of the preceding financial year has to be submitted in

         support of the claim for fixation of special rate.

         (ii)   that for the purpose of calculation of actual value

         addition, as per the prescribed format, relevant figures from

         the audited Balance Sheet have been extracted, which has

         been enclosed along with each application. Hence, it is not a

         case that a separate Balance Sheet was prepared for the

         purpose of special rate fixation, as contended by the Learned

         Commissioner, in the impugned Orders. In other words, an

         extract of Balance Sheet containing figures required for

         computation, in a format exclusively to suit the calculation of

         value addition was enclosed, which gets evidenced from the

         Notes accompanying the said extract of Balance Sheet, to the

         effect that the said extracted Balance Sheet has been

         prepared solely for the purpose of and as basis for claim of

         fixation of special rate.
                                        15


                        Excise Appeal Nos.197,198/2010, 477,478/2012,
                                71266,71267/2013, 75637-75639/2014,
                              76131,76132/2014, 75765-75770/2016 &
                                                   77120-77122/2017



         (iii)   that nowhere the Notification stipulates that copy of the

         Balance Sheet is to be enclosed. Instead, it just mandates

         that the value addition must be calculated based on the

         audited    Balance    Sheet    and   in   the   present   case,   the

         computation of value addition has been done based on the

         figures taken from such audited Balance Sheets only.

         (iv)    that considering the financial details of the year in

         question, instead of considering preceding financial years'

         details, in the applications made for fixation of special rate,

         would     be   more   accurate     and,   hence,   should   not   be

         questioned by Department.

3.3   He further submits that Section 211 of Companies Act, 1956

prescribes the form in which the Balance Sheet and Profit & Loss

Account of every Company registered under the said Act is to be

prepared, showing the true financial position of the said Company. It

stipulates that in order to give true and fair picture of the state of

affairs of the Company at the end of the financial year, the format as

prescribed in Part-I of Schedule VI has to be adopted for preparation of

the Balance Sheet and Profit & Loss Account. The Balance Sheet

prepared by the Appellants is in a consolidated form, in the sense that

all its Units located all over the country have been brought under the

common Balance Sheet and Profit & Loss Account. In other words, the

said consolidated Balance Sheet of the Company gives the true picture
                                     16


                       Excise Appeal Nos.197,198/2010, 477,478/2012,
                               71266,71267/2013, 75637-75639/2014,
                             76131,76132/2014, 75765-75770/2016 &
                                                  77120-77122/2017



of the functioning or the financial position of the Company (the

Appellants) as the whole. Hence, the Balance Sheet prepared is very

much in conformity with the provisions of Companies Act and the

findings of the Commissioner that statement of value addition based on

the said Balance Sheet and Profit & Loss Account does not bear any

legal sanctity is not correct and not sustainable. Adopting any other

method for preparing the Balance Sheet would lead to violation of the

provisions of Companies Act and Income Tax Act. In a nutshell, the

figures in the Extract of Balance Sheets, based on which the value

addition has been calculated, is very much in conformity with

Companies Act as well as with the Income Tax Act. Under these factual

circumstances and compliance of provisions of law, rejecting the

application for special rate fixation on a ground that the Balance Sheet

is not in conformity with the Companies Act, 1956, is incorrect and

unsustainable.

3.4      He further submits that the Explanation to Para 4 of

Notn.No.32/99-CE prescribes the formula to arrive at actual value

addition, based on financial records of the preceding financial year:

         (i)     Sale value of the said goods excluding excise duty,

                 Value Added Tax and other indirect taxes, if any, paid

                 on the goods;

         (ii)    Less: Cost of raw materials and packing materials

                 consumed in the said goods;
                                       17


                        Excise Appeal Nos.197,198/2010, 477,478/2012,
                                71266,71267/2013, 75637-75639/2014,
                              76131,76132/2014, 75765-75770/2016 &
                                                   77120-77122/2017



          (iii)   Less: Cost of fuel consumed if eligible for input credit

                  under CENVAT Credit Rules, 2004;

          (iv)    Plus: Value of said goods available as inventory in the

                  unit but not cleared, at the end of the financial year;

          (v)     Less: Value of said goods available as inventory in the

                  unit but not cleared, at the end of the financial year

                  preceding that under consideration.

From the above, it is clear that what is to be added is the inventory of

goods available at the end of each of the Financial Years and not

cleared. Similarly, the value of inventory not cleared at the end of the

financial year preceding to the Financial Year under consideration has

to be deducted. It may be relevant to note that the term "inventory"

would include stock of finished goods as well as stock of unfinished

goods in as much as some stock of goods may be incomplete or just

few steps/process away from the stage of completed finished product.

The said stock of incomplete/ unfinished goods, which have passed

through some processes and are yet to be subjected to some

processes to reach the final stage of production, are termed as 'work-

in-progress', which are also the part of the inventory, as per the

accounting standards. The aforesaid contention also gets support from the

following Accounting Standard (AS) 2 - Valuation of Inventories, issued by

the Institute of Chartered Accountants of India:

          "Inventories are assets:


          (a)     held for sale in the ordinary course of business;
                                           18


                             Excise Appeal Nos.197,198/2010, 477,478/2012,
                                     71266,71267/2013, 75637-75639/2014,
                                   76131,76132/2014, 75765-75770/2016 &
                                                        77120-77122/2017




            (b)       in the process of production for such sale; or
            (c)       in the form of materials or supplies to be consumed in
                      the production process or in the rendering of services.



3.5   He further submits that it is a settled position of law that once the

Department has not rebutted the evidences like Statutory Auditor's

certificates, as required under the Notification, the evidences brought

by assessee have to be accepted, based on the following judgments:


            (a)       Crane Betel Nut Powder Works - 2011 (274)
                      ELT 113 (T)
            (b)       (bi)    Crane Betel Nut Powder Works - 2012
                      (279) ELT 487 (A.P.)
            (c)  -do- Dept's appeal dismissed by SC- 2014 (305) ELT A-
            109 (SC)


3.6   He further submits that financial records as certified by the

Statutory Auditors would be the basis for calculation of actual value

addition for fixation of special rate. Hence, the actual value addition,

computed based on the figures from the audited financial records, is

correct and the special rate calculated based on the said value addition

is to be allowed.            It is a settled position of law that Statutory

Auditor's/CA's certificate is valid for arriving at the value addition,

based on the following judgments:

      (a)             Shree Narmada Khand Udyog - 2015 (329) ELT 820

                  (Tri)

      (b)         Bombay Dyeing & Mfg. Co. Ltd. - 2008 (223) ELT 514 (T)
                                     19


                      Excise Appeal Nos.197,198/2010, 477,478/2012,
                              71266,71267/2013, 75637-75639/2014,
                            76131,76132/2014, 75765-75770/2016 &
                                                 77120-77122/2017



3.7   He further submits that the inventory has to be considered as

per Explanation    to Para 2.1 of Notn.No.32/1999-CE and, hence,

Commissioner's findings that inventory in Depots and goods in transit

are not considered has got no relevance to the present case.

3.8    He further submits that In a similarly circumstanced facts and

issue, Hon'ble Tribunal, vide its Final Order No.60151/2023 dated

20.04.2023/06.06.2023, reported in 2023-TIOL- 548-CESTAT-CHD in

the case of Kokuyo Camlin Ltd., has held that resorting to and invoking

uniform   sales price; considering equalized      sales tax;    preparing

adjusted Balance Sheet/adjusted Profit & Loss Account, based on

whole company's Balance Sheet and Profit & Loss Account, etc., etc. is

proper and legal for arriving at value addition under area based

exemption Notification No. 56/2002-CE dated 14.02.2002. It has also

been held that Statutory Auditors' certificate cannot be questioned by

the Commissioner. Appreciating that applications made for fixation of

special rate under para 2.1 was accompanied with Statutory Auditors

certificate, which is the basis for computation of value addition, Hon'ble

Tribunal in Kokuyo Camlin was pleased to fix special rate, as certified

by the Statutory Auditors and claimed by the assessee therein. Kokuyo

Camlin's claim of fixation of special rate considering MRP based

assessment, however, was rejected.       The Hon'ble Tribunal judgment in

Osaka Alloys and Steels - [2015 (328) ELT 625 (Tri.-Del.)] also renders

persuasive support to the Appellants' contention of special rate based on

value addition.
                                      20


                       Excise Appeal Nos.197,198/2010, 477,478/2012,
                               71266,71267/2013, 75637-75639/2014,
                             76131,76132/2014, 75765-75770/2016 &
                                                  77120-77122/2017



3.9   He further submits that the findings of the Commissioner that

filing of applications for fixation of special rate was not done within the

time stipulated in the Notification would not be correct and also not

sustainable, in view of Hon'ble Guahati High Court judgment dated

12.08.2021 in the case of Jyothy Labs Ltd. - 2021 (378) ELT 269

(Gau) [para 16 to 21], wherein it has been held that the requirement

of making application for fixation of special rate has arisen after Hon'ble

Supreme Court judgment in V V F judgment dated 22.04.2020. It has

been held that the requirement of making such application not later than

30th September of a given financial year was a streamlining procedure

and, hence, the request made on 18.05.2020 (after V V F's judgment

dated 22.04.2020) was held to be not time barred. In the present case,

applications were made, from time to time, for each of the disputed

financial years, as detailed in list of events. Assuming, whilst denying,

that there is delay in filing the applications, the application filed in any

year would hold good for each of the subsequent financial years. For

example, the application filed in September 2009, for financial year

2008-09, can be considered as the application for financial year 2009-

10 and so on. In any case, the applications decided after three months

prescribed in Para 2.1(2) of the said Notification is not sustainable.

3.10 Finally, he submits that the Hon'ble Supreme Court in the

judgment & Order dated 22.04.2020 in the case of VVF (supra) has

specifically held that Notifications (No.17/2008-CE dated 27.03.2008
                                      21


                       Excise Appeal Nos.197,198/2010, 477,478/2012,
                               71266,71267/2013, 75637-75639/2014,
                             76131,76132/2014, 75765-75770/2016 &
                                                  77120-77122/2017



and 31/2008-CE dated 10.06.2008) are clarificatory in nature, since it

declares the refund of excise duty paid genuinely and paid on actual

manufacturing of goods and not on the duty paid on the goods

manufactured    only    on   paper    and   without   undertaking   any

manufacturing activities of such goods. The above contention further

gets substantiated from the findings in the said judgment.

3.11     He further submits that the recovery proceedings initiated by

the Dept., in view of the said Hon'ble Supreme Court judgment, were

challenged by the Applicants through Writ Petition WP(C) 3162/2019

and Hon'ble Gauhati High Court, in its Order dated 24.06.2020, has

directed the Respondents (i.e. UOI and jurisdictional Commissioner

and Assistant Commissioner) to re-visit the issue regarding the claims

sought for by the Petitioner in view of the judgment and order dated

22.04.2020 rendered by the Hon'ble Apex Court in the case of Union of

India v/s VVF Limited and, thereafter, take into consideration all the

claims made by the Petitioner as regards their entitlements to refund as

sought for in terms of the excise notification. He submits that invoking

the ratio laid down by the Hon'ble Supreme Court and Hon'ble Gauhati

High Court, the eligibility and quantum of refund has to be re-

determined.

3.12   He, therefore, prays that based on the above submissions and

those made in the grounds of appeals, all the 20 appeals, as has been
                                     22


                      Excise Appeal Nos.197,198/2010, 477,478/2012,
                              71266,71267/2013, 75637-75639/2014,
                            76131,76132/2014, 75765-75770/2016 &
                                                 77120-77122/2017



settled by the Tribunal in the case Kokuyo Camlin's case (supra), may

be allowed by setting aside the impugned orders.

4.    On the other hand, the ld.A.R. for the Revenue supported the

impugned orders and submitted that the applications of fixing of

special rate were filed after 3oth September of the same year beyond

time limit prescribed under the Notification and admittedly, the

appellants have filed these applications for special rate fixing in the

very next year. Therefore, the applications for special rate of fixing of

rates are not sustainable. In regard to balance sheet, he submits that

the balance sheets are not in conformity with Section 211 of the

Companies Act, 1956. He further submits that the gross sale value on

the average rate is not acceptable and the average rate of VAT is also

not acceptable. He further submits that the work in process cannot be

a part for taking value of sales and therefore, the appeals deserve to

be dismissed.

5.    Heard both the parties and considered the submissions.

6.    We find that the application for special rate fixing for the period

2009-10 to 2016-17 were initially held that they have filed the

applications for fixing special rate after 30th September of the same

year and is barred by limitation.

6.1   The said issue has been examined by the Hon'ble Apex Court and

the Hon'ble Apex Court in the case of Union of India Vs. V.V.F. Limited

reported in 2020 (372) ELT 495 (S.C.), has held that the pending
                                                23


                          Excise Appeal Nos.197,198/2010, 477,478/2012,
                                  71266,71267/2013, 75637-75639/2014,
                                76131,76132/2014, 75765-75770/2016 &
                                                     77120-77122/2017



refund     application     shall    be        decided      as    per     the   subsequent

notification/industrial     policies,     which        were     impugned       before   the

respective Hon'ble High Courts and they shall be decided in accordance

with     the   law   and     on     merits           and   as    per     the   subsequent

notifications/industrial policies impugned before the respective Hon'ble

High Courts. The extracted of orders of the Hon'ble Apex Court is as

under :

                     "........... subsequent notification / amendment in the

                 original notification did not in any way alter the basis

                 of the original first notification of 2001."

                 "..........       once        it     is     held     that     the   subsequent

                 notifications/industrial policies impugned before the

                 respective High Courts are clarificatory in nature and it

                 does not take away any vested rights conferred under

                 the earlier notifications/industrial policies, .......".

                 ".........that by the subsequent notifications/industrial

                 policies, the rights which have been accrued under the

                 earlier notifications had been taken away "

                 " On a fair reading of the earlier notifications/industrial

                 policies, it is clear

                 that the object of granting the refund was to refund the

                 excise duty paid on genuine manufacturing activities.

                 .................................................. ".
                                        24


                       Excise Appeal Nos.197,198/2010, 477,478/2012,
                               71266,71267/2013, 75637-75639/2014,
                             76131,76132/2014, 75765-75770/2016 &
                                                  77120-77122/2017



                "....... it is clarified by the subsequent notifications that

                the refund of the excise duty shall be on the actual

                excise duty paid on actual value addition made by the

                manufacturers undertaking manufacturing activities".

                "........ they do not take away any vested right conferred

                under the earlier notifications".

6.2    Further,the Hon'ble Guwahati High Court in the case of Jyoty

Labs reported in 2021 (378) ELT 269 (Gau.), has held that making

such   application   for   fixation   of    special    rate   under   Notification

No.32/99-CE and Notification No.31/2008-CE, after the judgement of

Hon'ble Supreme Court in the case of V.V.F. (supra) were in time.

6.3    In view of the above, we hold that as all the applications were

filed by the appellants before 20.04.2020.            In that circumstances, all

the applications were filed within time, therefore, the applications in

question cannot be rejected on limitation.

6.4    The remaining issue in all the appeals are common, therefore, all

are disposed off by a common observations as under :

6.5    The first issue is that the balance sheet is not in conformity with

Section 211 of the Companies Act, 1956. For better appreciation, the

facts of the relevant provisions under Notification No.32/99-CE dated

08.07.1999, are extracted herein under :
                                        25


                       Excise Appeal Nos.197,198/2010, 477,478/2012,
                               71266,71267/2013, 75637-75639/2014,
                             76131,76132/2014, 75765-75770/2016 &
                                                  77120-77122/2017




6.6   The clarification was given that in the area based exemption and

the   refund   of   duty   vide   letter    No.354/34/2004-TRU   (Pt)   dated

27.03.2008, the same is incorporated herein under :
            26


Excise Appeal Nos.197,198/2010, 477,478/2012,
        71266,71267/2013, 75637-75639/2014,
      76131,76132/2014, 75765-75770/2016 &
                           77120-77122/2017
                                     27


                       Excise Appeal Nos.197,198/2010, 477,478/2012,
                               71266,71267/2013, 75637-75639/2014,
                             76131,76132/2014, 75765-75770/2016 &
                                                  77120-77122/2017




6.7     The first ground for denial of special rate of fixation is that the

balance sheet is not in conformity with Section 211 of the Companies

Act, 1956 and there is no provision to prepare the balance sheet or

financial records under the provision of 211 of the Companies Act,

1956.
                                    28


                      Excise Appeal Nos.197,198/2010, 477,478/2012,
                              71266,71267/2013, 75637-75639/2014,
                            76131,76132/2014, 75765-75770/2016 &
                                                 77120-77122/2017




6.8    The said Section is incorporated herein under :




As per the said provisions, the profit and loss accounts and the balance

sheet of the Company shall comply with the accounting standards.

6.9   We find that a certificate from the Statutory Auditors, containing

the calculation of value addition based on the audited balance sheet of

the preceding financial year has to be submitted in support of the claim
                                      29


                        Excise Appeal Nos.197,198/2010, 477,478/2012,
                                71266,71267/2013, 75637-75639/2014,
                              76131,76132/2014, 75765-75770/2016 &
                                                   77120-77122/2017



for fixation of special rate.

6.10   We further take note of the facts that Section 211 of Companies

Act, prescribes the form in which the Balance Sheet and Profit & Loss

Account of every Company registered under the said Act is to be

prepared, showing the financial position of the said Company and the

balance sheet prepared by the appellants is in consolidated form, in the

sense that all its Units located all over the country have been brought

under the common Balance Sheet and Profit & Loss Account, but in

other words, the said consolidated Balance Sheet of the Company gives

the picture of the functioning or the financial position of the appellants

as the whole. Hence, the Balance Sheet prepared is very much in

conformity with the provisions of Companies Act and the findings of the

Ld.Commissioner that statement of value addition based on the said

Balance Sheet and Profit & Loss Account is not acceptable are in

conformity of law.

6.11   Further, we find that the figures in the Extract of Balance Sheets,

arem based on which the value addition, has been calculated, is very

much in conformity with Companies Act and the Income Tax Act.

6.12   Therefore, we hold that rejection of application for special rate

fixation on the balance sheet is not in conformity with the Companies

Act, 1956, is not correct.      On the said ground, the said application

cannot be rejected.

6.13   We take note of the fact that whether the statutory auditor's

report is acceptable or not ? We hold that that the statutory auditor's
                                     30


                      Excise Appeal Nos.197,198/2010, 477,478/2012,
                              71266,71267/2013, 75637-75639/2014,
                            76131,76132/2014, 75765-75770/2016 &
                                                 77120-77122/2017



report is acceptable in terms of the decision of this Tribunal in the case

of Commissioner of Central Excise & Customs, Guntur Vs. Crane Betel

Nut   Powder Works reported in 2011 (274) ELT 113 (Tri.-Bangalore),

wherein this Tribunal has observed as under :

       "5.1........................................... It             is   also       undisputed     that   the
      respondent-assessee     had   produced          a    detailed    Chartered
      Accountant certificate before the Adjudicating Authority, when the
      Adjudicating Authority issued a show cause notice to them for
      rejection of the refund claim. It is also undisputed and on records
      that the revenue had not produced any contrary evidence to
      evidence produced by the respondent-assessee in form of
      Chartered Accountant certificate for coming to such a conclusion
      that the respondent-assessee had passed on the burden to the
      customers.
       ........................................................................................................................

5.3 ................................................... It is seen from the records that as against the above detailed Chartered Accountant's certificate, revenue has not produced any contrary evidence to rebut the same except for claiming that the said certificate is devoid of any details. We find that the said Chartered Accountant's certificate as reproduced hereinabove clearly indicates that the Chartered Accountant (who was also the statutory auditor of the respondent-assessee) has given the certificate after going through the entire records of the respondent-assessee. In the absence of any effective rebuttal of the said Chartered Accountant certificate by leading a contrary evidence, we are of the considered view that the Chartered Accountant's certificate which indicates that the duty liability has not been passed on and has been absorbed 31 Excise Appeal Nos.197,198/2010, 477,478/2012, 71266,71267/2013, 75637-75639/2014, 76131,76132/2014, 75765-75770/2016 & 77120-77122/2017 by the assessee, cannot be rejected as an evidence in support of non-passing of the burden of incidence of duty. The said decision is affirmed by the Hon'ble Apex Court. We, therefore, hold that the statutory auditor's report is acceptable as an evidence.

7. Now, another issue raised by the ld.Commissioner that the gross sales value based on all India average rate is not acceptable.

8. We find that the products manufactured by the appellants were delivered to their depots from where the same were sold at a uniform selling price. The term uniform selling price indicates that there is uniform all India average rate prevalent at all the depots of the appellants and hence, multiplying the number of units cleared from the unit with the said all India average rate of selling price is the only and correct way of computing the gross sales value. The GSV was arrived at by taking all India Average rate of sales realization of the Company and the average rate of VAT at the rate of 12.5% has been deducted from the gross value. Since different States have different rates of Sales Tax, it is not possible for the appellant to identify as to what quantity of which product, stock transferred to their Depot, is sold in which State, in order to claim the amount of Sales Tax against that particular clearance. In view of this, the appellant has adopted the formula for computation to arrive at the average Sales Tax, which is as under :

Total sales tax paid all over India on a particular product,
-------------------------------------- x 100 = Average Sales Tax Total sales value of that product, paid in terms of Percentage.

9. We find that for the purpose of calculation of actual value addition, as per the prescribed format, relevant figures from the audited Balance Sheet have been extracted, which has been enclosed along with each application. Hence, it is not a case that a separate Balance Sheet was prepared for the purpose of special rate fixation, as held by the adjudicating authority. An extract of Balance Sheet containing figures 32 Excise Appeal Nos.197,198/2010, 477,478/2012, 71266,71267/2013, 75637-75639/2014, 76131,76132/2014, 75765-75770/2016 & 77120-77122/2017 required for computation, in a format exclusively to suit the calculation of value addition was enclosed, which gets evidenced from the Notes accompanying the said extract of Balance Sheet, to the effect that the said extracted Balance Sheet has been prepared solely for the purpose of and as basis for claim of fixation of special rate and nowhere the Notification stipulates that copy of the Balance Sheet is to be enclosed. Instead, it mandates that the value addition must be calculated based on the audited Balance Sheet and in the present case, the computation of value addition has been done based on the figures taken from such audited Balance Sheets only.

10. Further, an another reason for rejection of application is that the average rate of VAT at the rate of 12.5% is not acceptable.

11. The said issue has been settled by this Tribunal in the appellants' own case reported in 2016 (334) ELT 93 (Tri.-Chennai), wherein this Tribunal has held as under :

"3. After hearing both sides, and on perusal of records, we find that the appellants are engaged in the manufacture of Shampoo, Pure Petroleum Jelly (Vaseline) etc. The issue involved in these appeals is whether the appellants are eligible for abatement of equalized/averaged sales tax from transaction value under Section 4 of the Central Excise Act. According to the Revenue, the appellants have to claim sales tax abatement on actual basis. We find that Tribunal in the appellant's own case by Final Order No. A/1956/WZB/Mum/05/C-III/EB, dated 25-8-2005 following the decision of the Tribunal in the case of Zandu Pharmaceuticals v. CCE, Thane-II in Order No. A/370/WZB/2005- C-I, dated 5-4-2005 held that such deduction is permissible and set aside the impugned order.
33
Excise Appeal Nos.197,198/2010, 477,478/2012, 71266,71267/2013, 75637-75639/2014, 76131,76132/2014, 75765-75770/2016 & 77120-77122/2017
4. It is seen that the Tribunal subsequently vide Final Order No. A/361 & 362/13/EB/C-II, dated 16-4-2013 in the appellant's own case set aside the order and allowed the appeal. The relevant portion of the said decision is reproduced below :-
5. This issue came up before this Tribunal in appellant's own case wherein vide Order No. A/1956/WZB/Mum/05/C-III/EB, dated 25-8-2005 this Tribunal held that the Equalised Sales Tax can be allowed to be deducted. This issue again came up before this Tribunal in the case of Dabur India Ltd. - 2009 (247) E.L.T. 335 wherein this Tribunal observed as under :
7. We have carefully considered the submissions from both sides. There is no dispute about the eligibility for deduction on account of octroi and additional sales tax. The original authority has accepted this in principle. He has disallowed the deduction only based on the grounds that the respondent have claimed the same on a weighted average basis as mentioned earlier. The Commissioner (Appeals) have allowed the deduction without specifically giving a finding on each of the above three grounds raised by the original authority. We are of the considered view that in the given facts and circumstances of the case, the deduction towards additional sales tax and octroi can be allowed on equalised basis as has been done in the case of Apollo Tyres Limited cited supra. However, we are in agreement with the submissions of the learned DR that the said expenses have to be segregated exclusively in respect of excisable goods cleared by the respondent for the respective year. Therefore, to enable the same, we set aside the orders of the Commissioner (Appeals) and those of the original authority and remand the matter to the original authority to allow the deduction on the lines indicated above after granting reasonable opportunity of hearing to the 34 Excise Appeal Nos.197,198/2010, 477,478/2012, 71266,71267/2013, 75637-75639/2014, 76131,76132/2014, 75765-75770/2016 & 77120-77122/2017 party. The party shall produce relevant details within two months from the date of receipt of this Order and original authority shall dispose of the matter within four months thereafter.
6. Again this issue came up before this Tribunal in the case of Dabur India Ltd. [2013-TIOL-125-CESTAT-DEL = 2013 (295) E.L.T. 257 (T)] wherein also the same view was taken by this Tribunal.
7. Following the precedent decisions cited hereinabove of this Tribunal, which was accepted by the Revenue, we do not have any hesitation to hold that the appellant are entitled to claim deduction of Equalised Sales Tax from the transaction value to arrive at the assessable value."

5. In view of the above discussion, we hold that the appellants are entitled to claim the abatement of equalized sales tax from the transaction value. Accordingly, both the impugned orders are set aside and both the appeals are allowed with consequential relief. Stay applications are disposed of."

the said order has been affirmed by the Hon'ble Apex Court.

12. Therefore, we hold that the average rate of VAT at the rate of 12.5% is equalized the basis and the same is permissible for fixation of special rate. Hence, rejection of special rate of fixation, the applications cannot be rejected on that ground.

13. The next issue is that inclusion of work in progress is not correct.

14. The Explanation to Para 4 of Notn.No.32/99-CE is very much clear, which is as under :

35
Excise Appeal Nos.197,198/2010, 477,478/2012, 71266,71267/2013, 75637-75639/2014, 76131,76132/2014, 75765-75770/2016 & 77120-77122/2017
(i) "Sale value of the said goods excluding excise duty, Value Added Tax and other indirect taxes, if any, paid on the goods;
(ii) Less: Cost of raw materials and packing materials consumed in the said goods;
(iii) Less: Cost of fuel consumed if eligible for input credit under CENVAT Credit Rules, 2004;
(iv) Plus: Value of said goods available as inventory in the unit but not cleared, at the end of the financial year;
(v) Less: Value of said goods available as inventory in the unit but not cleared, at the end of the financial year preceding that under consideration.

Special rate would be the ratio of actual value addition in the production or manufacture of the said goods to the sale value of the said goods excluding excise duty, Value Added Tax and other indirect taxes, if any, paid on the goods."

From the above, it is clear that what is to be added is the inventory of goods available at the end of each of the Financial Years and not cleared. Similarly, the value of inventory not cleared at the end of the financial year preceding to the Financial Year under consideration has to be deducted. It may be relevant to note that the term "inventory"

would include stock of finished goods as well as stock of unfinished goods in as much as some stock of goods may be incomplete or just few steps/process away from the stage of completed finished product. The said stock of incomplete/ unfinished goods, which have passed through some processes and are yet to be subjected to some processes to reach the final stage of production, are termed as 'work-in-progress', which 36 Excise Appeal Nos.197,198/2010, 477,478/2012, 71266,71267/2013, 75637-75639/2014, 76131,76132/2014, 75765-75770/2016 & 77120-77122/2017 are also the part of the inventory, as per the accounting standards, which is as under :

"Inventories are assets :
(a) held for sale in the ordinary course of business ;
(b) in the process of production for such sale ; or
(c) in the form of materials or supplies to be consumed in the production process or in the rendering of services."

which means that the process of production on such materials i.e. work in process is the part of inventory and the appellants have correctly included the work in process in their stock. Therefore, we hold that the work in process is to be included in the opening stock and closing stock in computation of actual value addition.

15. In a nutshell, we take note of the fact that the issue of rejection of fixation of special rate on the above ground, came up before this Tribunal in the case of M/s Kokuyo Camlin Limited Vs. Commissioner of Central Excise & Service Tax, Jammu & Kashmir reported in 2023-TIOL-

548-CESTAT-CHD, wherein this Tribunal has observed as under :

"4. Heard both sides and perused the records of the case. Brief issue that requires consideration in the instant case is as to whether the Adjudicating Authority was correct in rejecting the appellant's claim for value addition in terms of Notification No. 56/2002-CE dated 14.11.2002 as amended. We find that on an application, dated 29.09.2009, made by the appellants, Commissioner vide letter dated 20.04.2010 informed the appellants that the value addition comes to 45.73% as against the claim of 58.6% or 62.65% by the appellants. We find that the 37 Excise Appeal Nos.197,198/2010, 477,478/2012, 71266,71267/2013, 75637-75639/2014, 76131,76132/2014, 75765-75770/2016 & 77120-77122/2017 appellants have submitted a detailed written reply and a Statutory Auditor's certificate to establish their claim.
5. We find that after giving a personal hearing on 11.05.2010, learned Commissioner has proceeded to adjudicate the case. Whereas in the letter dated 20.04.2010, Commissioner arrived at a value addition of 45.73%, while passing the final order, he rejected the claim completely. Commissioner has given the following findings: · In terms of Para 2.1 (l) of the Notification, it is the obligation of the manufacturer to stake their claim along with necessary documents and certificates and the appellants have failed to do so; burden to prove the claim is squarely on the appellants. 5 Excise Appeal No. 2630 Of 2010 · The word "Sale" is not defined under notification and therefore, the definition requires to be taken from Section 2 of Central Excise Act; the appellants claim of two value additions cannot be accepted; MRP value as contemplated under Section 4A of Central Excise Act, 1944 is a notional value and the same cannot be considered as a value for the purpose of the notification. · The application made by the appellants is dated 29.09.2009 and whereas the audited balance sheets are 30.09.2009 and therefore, cannot be accepted to be accurate in respect of various figures submitted. · As taken in the adjusted balance sheet, gross revenue cannot be considered as sale value; sale value requires to exclude Central Excise, VAT and other taxes; distribution of cost plus 10% on an average basis to all the sales is not acceptable.
6.We find that Commissioner has not discussed, in the impugned order, as to whether the appellants have arrived the calculations as above. However, he has discussed the same in the letter dated 20.04.2010 and made some additions and reductions in the claim of the appellants and arrived at the value addition of 45.73%. The appellants submit that: · Deduction the count of commission/ 38 Excise Appeal Nos.197,198/2010, 477,478/2012, 71266,71267/2013, 75637-75639/2014, 76131,76132/2014, 75765-75770/2016 & 77120-77122/2017 discount/ service charges; transport and forwarding charges; selling and distribution cost aggregating to Rs.38,52,223.18/- was incorrect as they have already come under profit & loss account. 6 Excise Appeal No. 2630 Of 2010 · Deduction of export value of Rs.5,84,119/- from the sale value is incorrect. · Cost of inter-unit transfer of semi-finished goods to Samba Unit which was already included in the cost of raw materials has been again included. · Commissioner erred in arriving at inventory values and adding freight inward to the cost of raw materials was incorrect. However, learned Commissioner has not discussed any of the above calculations in the impugned order and therefore, we do not find that there is any reason for us to go into the same in detail more so, when a Statutory Auditor's certificate is on record.
7. On-going through the records, we find that the learned commissioner, vide letter dated 20.04.2010, which is a show cause notice for the purposes of the impugned case, proposes to fix the value addition at the rate of 45.73% and vide final order totally rejects the claim of the appellant. Thus, we find that the Adjudicating Authority has gone beyond the scope of the Show Cause Notice. In case the learned Commissioner was to reject the claim totally, he should have put the appellants to proper notice in terms of principles of natural justice. As the proposal and final order are contrary to each other, we find that, in the instance case, the principles of natural justice have been grossly violated. Moreover, the Adjudicating Authority has not given any finding, whatsoever, on the Statutory Auditor's certificate, rebutting the certificate on the basis of cogent and reliable data and reasoning. The only finding that the Adjudicating Authority gives is that whereas the application is dated 29.09.2009, 7 Excise Appeal No. 2630 Of 2010 the Statutory Auditor's report is dated 30.09.2009 and therefore, it cannot be relied upon. The reasoning given by 39 Excise Appeal Nos.197,198/2010, 477,478/2012, 71266,71267/2013, 75637-75639/2014, 76131,76132/2014, 75765-75770/2016 & 77120-77122/2017 the learned Commissioner is not acceptable for the reason that the Statutory Auditor report was submitted before finalisation of the value addition by the Commissioner. We find that in terms of second Proviso to Para 2.1 (1), the manufacturer has to support his claim for a special rate with a certificate from his Statutory Auditor containing a calculation of value addition in the case of goods for which claim is made, based on the audited balance sheet of the unit for the preceding financial year. We find that the appellants have submitted the necessary certificate, it was therefore, incumbent upon the Adjudicating Authority to go through the Statutory Auditor's report; to question the figures adopted by the Statutory Auditor; to ask for clarification of the appellants before rejecting the same. Therefore, we find that Commissioner had no justified reasons to reject the Statutory Auditor's certificate. For this reason, we find that the Adjudicating Authority has completely ignored the provisions of the notification and therefore, such an order is liable to set aside.
8. We find that Explanation under Para 4 of the Notification reads as under: "For the purpose of this paragraph, the actual value addition in respect of said goods shall be calculated on the basis of the financial records of the preceding financial year, taking into account the following:
(i) Sale value of the said goods excluding excise duty, Value Added Tax and other indirect taxes, if any, paid on the goods;
(ii) Less: Cost of raw materials and packing material consumed in the said goods;
(iii) Less: Cost of fuel consumed if eligible for input credit under CENVAT Credit Rules, 2004;
(iv) Plus: Value of said goods available as inventory in the unit but not cleared, at the end of the financial year; 8 Excise Appeal No. 2630 Of 2010 (v) Less: Value of said goods available as 40 Excise Appeal Nos.197,198/2010, 477,478/2012, 71266,71267/2013, 75637-75639/2014, 76131,76132/2014, 75765-75770/2016 & 77120-77122/2017 inventory in the unit but not cleared, at the end of the financial year preceding that under consideration. We find that learned Adjudicating Authority has not given any findings on the above as to whether the calculations arrived by the appellants followed the above principles. The impugned order does not show any reasons to controvert the Statutory Auditor's report. Therefore, the calculations and figures as given by the Statutory Auditor require to be considered as held in Crane Betel Nut Powder Works (supra) and other cases cited above.

9. Having held that the rejection of the appellant's claim in the impugned order is incorrect, we are required to fix the percentage of value addition. We find that the appellants vide application dated 29.09.2009 and during the course of personal hearing on 11.05.2010, submitted that the value addition as applicable to them would be 58.60% ,if actual sale value is taken or 62.65%, if sale value is taken on MRP basis. We are in agreement with the findings of the Adjudicating Authority that MRP is a notional value and such value cannot be considered for the purposes of arriving at "Sale Value" in terms of the Notification No.56/2002-CE dated 14.11.2002. The actual sale value is to be considered. Therefore, we are inclined to accept the value addition at the rate of 58.60% as arrived by the appellants in their letter dated 29.09.2009 on the basis of figures that were certified by the Statutory Auditor. During the course of the argument and vide the written submissions, the appellants have arrived at a special rate of 60.38%. However, looking into the records of the case and the application dated 29.09.2009 submitted by the appellants and 9 Excise Appeal No. 2630 Of 2010 the Statutory Auditor's report, we find that the appellants are eligible for special rate of 58.60% as against the rate of 36% provided in the table of the said notification.

41

Excise Appeal Nos.197,198/2010, 477,478/2012, 71266,71267/2013, 75637-75639/2014, 76131,76132/2014, 75765-75770/2016 & 77120-77122/2017

10. In view of the above- the impugned order is set aside and the appeal is allowed fixing the special rate at 58.60%.

16. In view of the above discussions and observations, we hold that the rejection of the applications of fixation of special rate by the adjudicating authority is not correct and are in violation of law.

17. Therefore, we set aside the impugned orders and allow all the appeals by fixing the special rates as prayed by the appellants.

(Pronounced in the open court on 22.09.2023) Sd/ (Ashok Jindal) Member (Judicial) Sd/ (K.Anpazhakan) mm Member (Technical)