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Custom, Excise & Service Tax Tribunal

Abhishek Exports vs Commissioner Of Central Excise & ... on 18 May, 2026

     CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL
                                  NEW DELHI

                         PRINCIPAL BENCH- COURT NO. I

                     CUSTOMS APPEAL No. 51057 of 2025
(Arising out of Order-in-Original No. udz-excus-000-com-47-2024-25 dated 28.01.2025
passed by the Commissioner of Central Excise & CGST Commissionerate, Udaipur)

Abhishek Exporters                                          ....Appellant
H-208, Udyog Vihar,
Sukher, Udaipur
                                      Versus
Commissioner of Central Excise & CGST, Udaipur....Respondent
Udaipur, Rajasthan

                                     WITH

C/51060/2025;             C/51062/2025;             C/51063/2025;
C/51124/2025;             C/51199/2025;             E/51019/2025;
E/51061/2025;             E/51879/2025;             E/51880/2025;
E/51881/2025; and         E/51882/2025



APPEARANCE:
Mr. B.L. Narashimhan and Shri Anurag Kapur, advocates for the appellant
Mr. Ajay Jain, special counsel for the department

CORAM : HON'BLE MR. JUSTICE DILIP GUPTA, PRESIDENT
             HON'BLE MR. K ANPAZHAKAN, MEMBER (TECHNICAL)


                                         Date of Hearing : 14.05. 2026
                                         Date of Decision : 18.05.2026


                 FINAL ORDER NOS. 50917-51928/2026


PER: K. ANPAZHAKAN



1.    Customs Appeal Nos. 51199 of 2025, 51057 of 2025, 51124 of 2025,

51060 of 2025, 51062 of 2025 and 51063 of 2025 have been filed against

the impugned Order-in-Original no. UDZ-EXCUS-0000-COM-47&48-2024-

25 dated 28.01.2025.


1.1. Central Excise Appeal Nos. 51019 of 2025, 51061 of 2025, 51179 of

2025, 51880 of 2025, 51881 of 2025 and 51882 of 2025 have been filed
                                                        2
                                                                       C/51057/2025
against the same Order-in-Original No. UDZ-EXCUS-0000-COM-47&48-

2024-25 dated 28.01.2025.


1.2.     As all these appeals have been filed against the same Order-in-

Original and the issues involved in all these appeals are common, they are

taken up together for decision by a common order.


2.     The facts of the case are that M/s. Abhishek Exports (hereinafter

referred to as the "appellant") is a 100% Export Oriented Unit (EOU) inter

alia engaged in the manufacture and export of marbles. During the period

from 2002 to August 2005 ('disputed period'), the Appellant imported

Marble Blocks duty free, by availing the exemption provided under the

Notification Nos. 53/97- Cus. dated 03.06.1997 and 52/2003-Cus. dated

31.03.2003.


2.1. The imported Marble Blocks were cut into Marble Slabs / Tiles. The

said Marble Slabs / Tiles were exported as well as sold in the Domestic

Tariff Area ('DTA) upon grant of permission by the Development

Commissioner. The goods sold in the DTA were cleared upon payment of

applicable   Excise   duty   as   per   Notification       Nos.   02/95-CE   dated

04.01.1995 and 23/2003-CE dated 31.03.2003, i.e., at 50% of the import

duty leviable on like goods if imported into India.


2.2. The Appellant also domestically procured Serpentine Marble Blocks,

cut them into Serpentine Slabs/ Tiles and exported the same.


3. The chronology of events leading to the present appeals is tabulated

below:
                                            3
                                                     C/51057/2025




             Particulars
Date


             Show Cause Notice No.
16.05.2005
             V(25)15/Off/Adj-

             II/15/05/2596                dated

             16.05.2005         issued         for

             period2002-2005,

             alleging that the Marble

             Blocks      imported          duty

             free were converted into

             Marble Slabs/ Tiles and

             cleared      in        the     DTA

             resulting     in        incorrect

             availment         of    Customs

             Notifications and Excise

             Notifications benefits. It

             was also alleged that

             Appellant did not follow

             the EXIM Policy 2002-

             2007     ('EXIM         Policy')

             and Foreign Trade Policy

             2004-2009 ('FTP').



             Show        Cause            Notice
08.11.2005
             No.V(25)15/Off/Adj-

             II/116/05/85841 dated

             08.11.2005         issued         for
                                         4
                                                  C/51057/2025
             period     April    2005        to

             August         2005,       with

             allegations        same        as

             above.



             Reply     to     show     cause
05.09.2005
             notice                    dated

             16.05.2005,        was     filed

             inter     alia     submitting

             that      the       Appellant

             processed the imported

             Marble         Blocks      and

             cleared them into DTA

             upon        payment             of

             applicable       excise    duty

             and         under          due

             permission          of         the

             Development

             Commissioner.            Hence,

             there was no violation

             of the Customs/ Excise

             Notification.

             Accordingly,        it     was

             requested to drop the

             proceedings          initiated

             vide     the     show     cause

             notice.
                                         5
                                                  C/51057/2025
             Reply     to    show    cause
10.03.2006
             notice                  dated

             08.11.2005,       was      filed

             on     similar     lines       as

             above and requesting to

             drop     the     proceedings

             initiated vide the show

             cause notice.



             Order-in-Original          No.
24.04.2006
             12-13/CE/JP-II/2006

             dated            24.04.2006

             ('Order                 dated

             24.04.2006')           passed

             by        the       Learned

             Commissioner,           Jaipur,

             confirming                     the

             allegations in the above

             show cause notices.




             Appeals filed before the

             Hon'ble        CESTAT      New

             Delhi, against the above

             Order                   dated

             24.04.2006.
                                        6
                                                           C/51057/2025
             Decision passed by the
17.02.2009
             Hon'ble        CESTATNew

             Delhi   in    an    identical

             issue in the case of M/s

             Jain       Grani        Marmo

             Pvt. Ltd. & Ors. vs.

             CCE, Jaipur-II, Final

             Order        Nos.       C/84-

             85/09                   dated

             17.02.2009          (referred

             to      elsewhere         and

             hereinafter        as     'Jain

             Grani'),     wherein          the

             following was inter alia

             held:

             a. process of cutting of Marble

                  Blocks into slabs/ tiles did

                  not amount to manufacture.

                  Hence, excise duty was not

                  payable under the Central

                  Excise    Act, 1944 ('Excise

                  Act');and


             b. extended period of limitation

                  under     proviso        to    Section

                  28(1) of the Customs Act,

                  1962 ('Customs Act') was

                  not invokable.
                                            7
                                                              C/51057/2025

             Miscellaneous

             Application                   No.

             C/Misc./579/2009              filed

             by     the        Appellant        in

             Customs           Appeal     Nos.

             C/489-491/2006inter

             aliaon       the      following

             questions of law:

             a. No excise duty is payable as

                  the process of cutting Marble

                  Blocks         into    Marble      Slabs/

                  Tiles does not amount to

                  manufacture; and


             b. Excise duty paid is liable for

                  adjustment against Customs

                  duty demand.



             Decision passed by the
10.06.2010
             Hon'ble       CESTAT          New

             Delhi        in      Abhishek

             Exports                           vs.

             Commissioner                      of

             Central                    Excise,

             Jaipur-II, Final Order

             Nos.      C/86-88/2010

             and Misc. Order No.

             C/81/2010                   dated
                                        8
                                                 C/51057/2025
             10.06.2010         disposing

             of    the   miscellaneous

             application               and

             remanding the           matter

             for re-adjudication after

             considering the decision

             in Jain Grani (supra)

             and   additional        ground

             taken by the Appellant.




             The show cause notices

             dated 16.05.2005 and

             08.11.2005 were kept

             in call book due to the

             pendency        of            the

             department's            appeal

             against     Jain        Grani

             (supra)       before          the

             Hon'ble Supreme Court.



             Judgement          of         the
02.08.2023
             Hon'ble Supreme Court

             vide Commissioner of

             Central              Excise,

             Jaipur-II      vs.        Jain

             Grani Marmo Pvt Ltd,

             Civil Appeal Nos. 255-

             256/2010                dated
                       9
                               C/51057/2025
02.08.2023, dismissing

the departmental appeal

due to low tax effect.




The show cause notices

dated 16.05.2005 and

08.11.2005            were

retrieved from the call

book and were taken up

for   adjudication        by

Learned      Commissioner,

Central      Excise   and

CGST Commissionerate,

Udaipur          ('Learned

Commissioner,

Udaipur').
                                        10
                                                       C/51057/2025
             Written         submissions
23.12.2024
             filed by the Appellant

             pursuant to the remand

             proceedings      inter    alia

             submitting that:

             a. The decision in Jain Grani

                  (supra) is binding on the

                  lower authorities;


             b. The     Customs         and   Excise

                  Notifications        have    been

                  correctly availed; and


             c. Excise duty demand is not

                  sustainable since there is no

                  manufacture.



             Passing    of        Order-in-
28.01.2025
             Original       No.       UDZ-

             EXCUS-000-COM- 47 &

             48-2024-25               dated

             28.01.2025       inter    alia

             confirming the demand

             of   customs     duty     and

             excise duty.
                                                                  11
                                                                                 C/51057/2025
            3.1.         The details of the impugned demands of duty and penalties

            contested by the appellants in these Customs Appeals and Excise Appeals

            are tabulated below: -


EXCISE APPEALS

Excise             Abhishek Exports 1: Appeal No: Abhishek Exports 2: Appeal No:

Appeal Nos         E/51061/2025                           E/51019/2025

                   Paras    Rajghariya   1:Appeal     No: Paras Rajghariya 2: Appeal No:

                   E/51881/2025                           E/51880/2025

                   Prabhas Rajghariya 1: Appeal No: Prabhas Rajghariya 2: Appeal No:

                   E/51882/2025                           E/51879/2025

Excise duty Rs. 96,53,506/- as per proviso to Rs. 58,82,329/- as per proviso to

demand on S.11A(1) of Central Excise Act.                 S.11A(1) of Central Excise Act.

Appellant

Excise             Rs.     96,53,506/-   u/s   11AC    of Rs.   58,82,329/-     u/s   11AC      of

Penalty     on Central Excise Act.                        Central Excise Act.

Appellant

Excise             Rs. 2,50,000/- under Rule 26 of Rs. 2,50,000/- under Rule 26 of

Penalty     on Excise Rules                               Excise Rules

Co-                Rs. 2,50,000/- under Rule 26 of Rs. 2,50,000/- under Rule 26 of

Appellants         Excise Rules                           Excise Rules




CUSTOMS APPEALS

Customs            Abhishek Exports 3: Appeal No: Abhishek Exports 4: Appeal No:

Appeal             C/51199/2025                           C/51057/2025

Nos.               Paras Rajghariya 3: Appeal No: Paras Rajghariya 4: Appeal No:

                   C/51060/2025                           C/51124/2025
                                                                12
                                                                               C/51057/2025
                 Prabhas Rajghariya 3: Appeal No: Prabhas Rajghariya 4: Appeal No:

                 C/51062/2025                           C/51063/2025

Customs          Rs. 2,13,87,141/- as per proviso to Rs. 35,45,401/- as per proviso to

duty             S.28(1)   of   Customs      Act   (Rs. S.28(1)     of   Customs   Act    (Rs.

demand           1,75,37,719 pertains to extended 10,72,637 pertains to extended

                 period demand).                        period demand).

Customs          Rs.   2,13,87,141/-   u/s   114A   of Rs.    35,45,401/-    u/s   114A       of

penalty     on Customs Act.                             Customs Act.

Appellant

Customs          Rs. 2,50,000/- u/s 112 of Customs Rs. 2,50,000/- u/s 112 of Customs

penalty     on Act                                      Act

Co-              Rs. 2,50,000/- u/s 112 of Customs Rs. 2,50,000.- u/s 112 of Customs

Appellants       Act                                    Act

Redemption

fine        on Rs.50,00,000/- u/s 125 of the Customs Act.

Appellant


            4. Aggrieved by the demands of Customs and Central Excise duties

            confirmed in the impugned Order-in-Original dated 28.01.2025, along

            with interest and penalties, the present appeals have been preferred

            before the CESTAT, New Delhi.


            5.   Regarding the demand of central excise duty confirmed in the

            impugned order, the learned Counsel appearing on behalf of the

            appellants submitted that they have under taken the process of cutting

            the marble blocks imported by them; the said process of cutting the

            marbles into marble slabs/tiles does not amount to 'manufacture' as

            defined under Section 2(f) of the Central Excise Act, 1944. As per Chapter

            Note 6 to Central Excise Tariff, in relation to products of CTH 2515
                                                      13
                                                                   C/51057/2025
(marble etc) and 2516 (granite etc), the process of cutting or sawing or

sizing or any other process, for converting of stone blocks into slabs or

tiles shall not amount to 'manufacture' during the relevant period; A

separate Chapter Note enabling the process of converting of stone blocks

into slabs or tiles as amounting to 'manufacture' has been introduced in

the Central Excise Tariff only in April 2006. It is argued by the appellants

that since the Chapter Note was not in effect during the disputed period,

the process carried out by the appellant i.e., cutting of imported marble

blocks   into   marble   slabs/tiles   does   not   amount to   'manufacture'.

Accordingly, the learned Counsel for the appellants contended that the

demand of central excise duty confirmed in the impugned order is legally

not sustainable.


5.1. In support of their contention, the appellants placed reliance upon

the following decisions:


   i. Jain Grani Marmo Pvt Ltd. vs. Commissioner of Central Excise,

   Jaipur (supra), wherein on similar facts and Circumstances, the

   Tribunal has held that the process of cutting of imported marble blocks

   into marble slabs/tiles does not amount to 'manufacture'.


   ii. Aman Marble Industries Pvt. Ltd. vs. Commissioner of

   Central Excise, 2003 (157) E.L.T. 393 (SC),wherein it was held

   that no new substance is formed on cutting of marble bocks into slabs,

   therefore it does not amount to manufacture;


   iii. Rajasthan SEB vs. Associated Stone Industries, (2000) 6

   SCC 141, wherein the court held that cutting/polishing of marbles into

   slabs does not amount to manufacturing of goods.


   iv. Hindustan Granites vs. Commissioner of Central Excise,

   Bangalore-I, Final Order No. 20862/2025 dated 19.02.2025.
                                                   14
                                                                 C/51057/2025
5.2. Thus, it is the case of the appellants that the said issue is no longer

res integra as the same stands settled by the decision of the Tribunal in

the case of Jain Grani where the Tribunal has categorically decided that

no central excise duty was payable in respect of DTA clearance of Marble

Slabs/ Tiles, since the process of cutting of Marble Blocks into slabs/ tiles

did not amount to 'manufacture'. It has been pointed out that the appeal

filed by the department against the said case was dismissed by the

Hon'ble Supreme Court in view of the low tax effect; it is submitted that

since the decision of the Tribunal in Jain Grani was neither modified nor

overruled, the learned Commissioner ought to have followed the same, in

so far as it held that the excise duty was not payable as there was no

'manufacture' involved in the said process.


5.3. Relying on the decisions cited supra, the learned Counsel for the

appellants submits that the demand of central excise duty confirmed in

the impugned order is legally not sustainable, thus contending that the

impugned order is liable to be set aside to the extent the excise duty is

demanded.


6. Regarding the demand of Customs duty vide the impugned order, the

learned Counsel for the appellants makes the submission that the facts of

the present case are similar to the facts and circumstances of Jain Grani

and hence the said decision is squarely applicable to the present case. He

explained that in Jain Grani, the Tribunal has held that the condition for

duty free import by a 100% EOU, as prescribed in Notification No. 52/03-

Cus. has not been fulfilled in respect of imported marble blocks and,

therefore, the same are not eligible for duty exemption. Since these

marble blocks, after their use have not been used for the intended

purpose, the appellant was held to be liable to pay custom duty; however,

the customs duty demanded has been restricted to normal period of
                                                  15
                                                                C/51057/2025
limitation, as the Department was well aware of the activities of the

appellant being a 100% EOU and no suppression of facts with intention

to evade the tax established. Thus, following the ratio of the decision of

the Tribunal in Jain Grani, the appellants submit that the demand of

customs duty confirmed in the impugned order is to be restricted to the

normal period of limitation and the demand confirmed in the impugned

order by invoking the extended period of limitation is liable to be set

aside. In view of these submissions, the learned Counsel for the

appellants prayed for setting aside the demand of customs duty confirmed

in the impugned order by invoking the extended period of limitation.


7. The appellants have further submitted that in Jain Grani, it has been

categorically held that the conversion of marble blocks into marble slabs

does not amount to 'manufacture' and no excise duty is payable on the

clearance of marble slabs/tiles into the DTA. Therefore, it is their case

that the duty already deposited by the appellant should be adjusted

against the demand of customs duty, if any, confirmed for the normal

period of limitation.


7.1. In support of their claim for adjustment of central excise duty paid

against the customs duty liability, the appellants placed their reliance on

the decision of the Tribunal in Nikhil Industries Pvt. Ltd. vs.

Commissioner of Central Excise, 2005 (180) E.L.T. 321 (Tribunal),

wherein it has been held that duty already paid by the EOU on the

finished goods was adjustable against the duty leviable on the raw

materials. They have also cited the decision of the CESTAT, Kolkata in the

case of South Asian Petrochem Ltd vs. C.C. (Airport & Admn.)

Kolkata, 2007 (219) E.L.T. 991 (Tri. -Kolkata) wherein it was held

that duty paid in excess under one head can be adjusted against duty

short paid under a different head, insofar as the duties are paid to the
                                                16
                                                             C/51057/2025
Central Government; the above decision was affirmed by the Calcutta

High Court in Commissioner vs. South Asian Petrochem Ltd, 2009

(233) E.L.T. A133 (Cal.)


7.2. The learned Counsel for the appellant also submitted the details of

excise duty paid and customs duty demanded, which have been tabulated

below:


                           Amount        Amount       Total amount
Particulars
                           (SCN 1)       (SCN 2)


                                         47,62,252    64,29,943
Excise Duty paid           16,67,691



Customs duty demanded:
                           2,13,87,142   35,45,401
 Total duty demanded
                           (1,75,37,719 (10,72,637
 Less: Extended period
                           )             )            63,22,187
 Normal period demand
                           38,49,423     24,72,764



Amount paid in excess                                 1,07,756




7.3. From the above table, it can be seen that out of the total customs

duty demanded, if the demand pertaining to the extended period is

excluded, then the balance customs duty demand pertaining to normal

period of limitation amounts to Rs. 63,22,187/-. However, the appellant

has paid duty at the time of DTA clearance duty to the tune of Rs.

64,29,943/-, which when adjusted against the customs duty demand,

results in excess duty paid to the extent of Rs. 1,07,756/-. Thus, the

appellant makes the submission in this regard that no additional amount
                                                        17
                                                                         C/51057/2025
remains payable in the present case and the Impugned Order is liable to

be set aside to this extent.

8.     The learned Counsel for the appellant also contends that the

extended period of limitation cannot be invoked as there was no collusion

or wilful misstatement or suppression of facts established in this case. He

submitted that the appellants have not suppressed any information

regarding     imports/    procurement   and    exports/      clearance   from     the

authorities; that they have been filing ER-1 returns regularly containing

all necessary details of activities undertaken by it. Further, it is pointed

out that the packages/ containers for export were examined and certified

by the jurisdictional central excise officers. Further, the Marble Slabs/ Tiles

were cleared into DTA pursuant to obtaining permission from the

Development Commissioner. Since the facts pertaining to the transactions

undertaken     by   the   Appellant   were    within   the    knowledge      of   the

department, it is contended that the extended period of limitation cannot

be invoked.

8.1.   In this regard, the appellant has also drawn attention to the fact

that in Jain Grani, it was held that extended period of limitation was not

invokable since data pertaining to import and export activities of EoUs,

was already available with the department. The appellants further

submitted that in the case of Rallison Electricals Pvt Ltd vs. Principal

Commissioner of Central Goods & Services Tax, Commissionerate,

Alwar, Final Order No. 50752/2026 dated 21.04.2026 , the Tribunal

has held that extended period of limitation cannot be invoked citing

suppression of facts since the assessee regularly filed ER-1 returns and

nothing prevented the officers from seeking more information from the

assessees. Thus, the appellants put forth the submission that the

demands confirmed by invocation of the extended period are not

sustainable in these cases.
                                                   18
                                                                C/51057/2025
8.2. Additionally, the learned Counsel for the appellants also submitted

that the Bond    executed by them cannot be invoked to overcome the

statutory provisions governing extended period of limitation; that the

Adjudicating authority has inter alia ordered to demand customs duty

under proviso to Section 28(1) read with B-17 bond furnished by the

appellant; it is a settled principle of law that demand can be raised for

extended period only when the ingredients mentioned therein are present.

In support of this view, he relied on the decision of the Tribunal in

Commissioner of C. Ex., Pune-I vs. Emcure Pharmaceuticals Ltd,

2014 (307) E.L.T. 180 (Tri. - Mumbai), wherein it was held that

merely because the assessee executed a B-17 bond they would not fall

outside the purview of Section 11A; the above decision was affirmed by

the Bombay High Court in Commissioner of C. Ex., Pune-I vs. Emcure

Pharmaceuticals Ltd, 2016 (342) E.L.T. 172 (Bom). Thus, it is

submitted that when the relevant facts about the activities undertaken by

the appellant were within the knowledge of the department, duty cannot

be demanded for extended period of limitation. It is the appellant's case

on this score that relying on B-17 bond to uphold the demand irrespective

of the limitation period would result in making the statutory provisions

redundant. Thus, the appellant also contends that the demand for the

extended period confirmed by invoking the B-17 Bond executed by the

appellant is legally not sustainable.

9. Furthermore, the appellant submits that the marble blocks are not

liable for confiscation and the redemption fine not imposable in this case;

that provisions of Section 111(d) and 111(o) of the Customs Act are not

invokable as regards the Marble Blocks in the present case inasmuch as

neither their import is prohibited, nor has there been any non-observance

of any condition surrounding their import. Further, it is submitted that the

Marble Blocks are not liable for confiscation because they have been
                                                     19
                                                                     C/51057/2025
converted into Marble Slabs/ Tiles and also cleared into DTA; they are no

longer physically available.

9.1. In support of the contentions hereinabove, reliance is placed by the

appellants   on   the   decision   of   the   Tribunal   in   M/s.   Mahindra

Aerostructures Pvt. Ltd. and M/s. Tangirala Subrahmanya Sarma,

DGM vs. Commissioner of Customs, Chennai, Final Order Nos.

40472 & 40473/2025 dated 24.04.2025, wherein it was held that for

confiscation of goods, both liability and availability of the goods are

necessary; that further, in the Appellant's own case in Abhishek Exports

& Ors. vs. Commissioner of Customs, Jodhpur Headquarters,

Jaipur, Final Order Nos. 50325-50334/2026 dated 09.03.2026, the

Tribunal held that Marble Blocks were not liable for confiscation under

Sections 111(d) and (o) of the Customs Act since their import was neither

prohibited nor was any import condition violated. They also submit that

since the marble blocks had been already used in the manufacture of

Marble Slabs/ Tiles and not available, they were not liable to confiscation.

It was also held that redemption fine under Section 125 of the Customs

Act was not imposable since the goods therein were not confiscated.

Therefore, in view of the above decisions, it is submitted that Marble

Blocks are not liable for confiscation and redemption fine is not imposable.

10. Regarding the demand of customs duty confirmed in the impugned

order, Shri Ajay Jain, learned Special Counsel appearing for the Revenue

submits that the demand of customs duty on imported marble has already

been canvassed before the Tribunal as well as High Court of Rajasthan in

the Jain Grani. He submits that the issue regarding demand of customs

duty in a case where the imported inputs have not been used for exported

goods at all, has attained finality and hence the appellants are liable to

pay the customs duty as demanded in the impugned Order-in-Original.

Regarding restriction of the customs duty for the normal period of
                                                   20
                                                                C/51057/2025
limitation, the learned Special Counsel submits that though it has been

contended by the appellants that the Department was aware of all of their

activities namely procurement of material from domestic sources, import

of marble blocks, exports made by them and the domestic clearances and

the extended period cannot thus be invoked against them, the appellant

have not declared the correct description of the goods in the documents

filed before Customs Authorities; he submits that the appellant has

declared the description of goods as 'Polished Marble slabs' in the

Shipping Bills and the corresponding invoices. He states that in the ARE-1

also the description was declared as 'Polished Marble Slabs'; in ARE-3, the

description was declared as 'unpolished Marble slabs'; In the Bill of Entry,

the description was 'Rough Marble Blocks'; the description on the

document by which the goods were cleared in DTA is not available. From

these descriptions, he submits, it was not possible to find out as to

whether the goods exported have been obtained from imported inputs or

indigenous inputs.   In view of the above factual position, it has been

argued by the learned Special Counsel for the Revenue that the

contention of the appellants that the demand of customs duty can be

made only for the normal period is not correct and accordingly, submits

that the appellants are liable to pay the customs duty as demanded in the

impugned Order-in-Original.

10.1. Regarding the demand of excise duty confirmed in the impugned

order, the learned Special Counsel for the Revenue relied upon the

findings of the learned adjudicating authority in the impugned Order-in-

Original in paragraphs 54-57, wherein the adjudicating authority has

observed that DTA sale was available to the appellant only by virtue of

para 6.8 of Exim Policy/ FTP and provisions made in Central Excise Act;

EOU Scheme now encompasses activities such as packaging, processing

and rendering services which in strict terms are not termed as
                                                     21
                                                                     C/51057/2025
'manufacture' but a broader meaning of manufacture as given in Exim

policy/ FTP is to be taken in respect of goods manufactured or produced in

a 100% EOU and cleared into DTA; this interpretation should be in terms

of provisions of Exim policy/ FTP and not in terms of section 2(f); there

cannot   be   two   different   stands   for   interpretation   of   the   word

'manufacture' for the purpose of goods manufactured/ produced in 100%

EOU and for the purpose of extending benefit of Notification No. 23/2003-

CE dated 31.03.2003 in respect of goods so manufactured / produced in

such EOU. The learned Special counsel referred to CCE, New Delhi vs

Weston Electronic reported at 2000(116) ELT 181 (Tribunal); Oracle Info

tech (P) Ltd. vs CCE, New Delhi reported at 2003 (151) ELT 656 (Tri-

Delhi); Super Cassettes Industries Ltd. vs CCE reported at 1998 (104)

ELT 115 (Tri-Delhi); Precision Processors (India) (P) Ltd. vs Commissioner

of Customs reported at 2007 (216) ELT 233 (Tri-Kolkata) and contended

that all these decisions are in line with the Board's Circular No. 314/30/97

dated 06.05.1997 wherein it was stated that the EOU scheme covers even

those activities which may not be strictly considered as manufacture

under Section 2(f) of the Central Excise Act, 1944. In this context, he

further submits that the Department had filed an appeal before the

Supreme Court against the order of the Tribunal in Jain Grani; the said

appeal was dismissed on 02.08.23 by the Hon'ble Supreme Court on

account of low tax effect involved; however, the point of law was left

open. He submitted that the case laws relied upon by the Hon'ble Tribunal

in Jain Grani case were relating to the excise duty applicable in the DTA

production and the case laws referred to by the Commissioner are relating

to the broader concept of manufacture in case of EOUs. Thus, it is the

contention of the Learned Special Counsel for the Revenue that the

decision of the Tribunal in Jain Grani is distinguishable. Accordingly, he
                                                  22
                                                                C/51057/2025
argued that the demand of central excise duty confirmed in the impugned

order is legally sustainable.

10.2. Regarding the claim of the appellant that the central excise duty

already deposited at the time of DTA clearance of the marble slabs should

be adjusted against the demand of custom duty, if any, confirmed for the

normal period of limitation, the learned Special Counsel opposes the same

and submits that central excise duty was paid by the appellant on

domestic clearances during the period 2002-August 2005, which is the

period for which show cause notices have been issued to them; however,

the various judgements which the Tribunal has relied upon in Jain Grani to

arrive at the conclusion that no excise duty was payable, pertains either

to the period prior to the impugned clearances or during that period. He

submits that despite these decisions, the appellants were paying

excise duty at concessional rate for their DTA clearance without

any demur.      It is further submitted that as per the decision of the

Supreme Court in Mafatlal Industries, if an assessee pays the duty based

on a wrong understanding, he is still governed by the Refund provisions of

the Act and therefore, any demand of Customs duty cannot be

automatically adjusted against the central excise duty which was paid by

them under a clear notion that they are liable to pay this duty; therefore,

as far as the payment of central excise duty is concerned, they are

required to go through the route of refund under Section 11B; that the

same will be subjected to fulfilment of various legal requirement including

the provisions of unjust enrichment. Accordingly, the learned Special

Counsel submits on this issue that the case laws relied upon by the

appellants in support of their claim for adjustment are distinguishable and

hence the request of the appellants for adjustment of the central excise

duty paid against the customs liability, if any, confirmed for the normal

period of limitation cannot be accepted.
                                                         23
                                                                     C/51057/2025
11. The submissions advanced by the learned Counsel for the appellant

and   the   learned    Special   Counsel    for   the   department   have    been

considered.

12. From the facts of the case, it is seen that the appellant, namely, M/s.

Abhishek Exports, is a 100% EOU. It had imported rough marble blocks

and availed duty exemption thereon in terms of Notification No. 53/97-

Cus, 52/2003-Cus and Notification Nos. 2/95-CE and 23/2003-CE. It was

procuring serpentine marble slabs indigenously on which no central excise

duty was leviable. During the period 2002 to August,2005, the appellant

exported products produced out of indigenously procured serpentine

marble. On the basis of this export performance, it sold marble

manufactured out of imported marble in the DTA in terms of FTP and paid

excise duty which was equal to 50% of the customs duty applicable on the

like imported goods in terms of proviso to Section 3 of Central Excise Act,

1944. As per the provisions of Exim Policy and FTP, the appellant was

required to first export the goods made out of the rough marble blocks,

only then they were entitled to clear the marble blocks, slabs and tiles in

the DTA. Since they exported slabs and tiles made out of indigenously

procured serpentine marble, they were not entitled to clear the products

manufactured out of imported material in DTA at concessional rate of 50%

of the applicable rate. Since the marble blocks imported have not been

used for the intended purpose, the appellant was held to be liable to pay

custom duty.

12.1. In this regard, we find that an identical issue in the case of another

EOU unit, M/s Jain Grani Marmo Pvt. Ltd. was decided by the

Tribunal      vide    Final   Order   No.     C/84-85/2009       (PB)       dated

17.02.2009. It was held by the Tribunal that serpentine marble and

marble are not similar goods hence exemption from customs duty under

notification No. 52/2003-Cus on import of marble was not available. M/s.
                                                  24
                                                                C/51057/2025
Jain Grani filed an Appeal No. 126-127 /2009 before the High Court of

Rajasthan. It was prayed that the order of the Tribunal relating to

confirmation of Customs duty on imported inputs is liable to be set aside.

The High Court by order dated 21.02.2025 decided the appeals and

upheld the order of the Tribunal as far as the confirmation of Customs

duty for the normal period of limitation is concerned. The Department had

filed Appeal Nos. 255-256/2010 before the Supreme Court against the

part of Tribunal order wherein it was held that the central excise duty was

not leviable on mere slitting of marble stones. By order dated 02.08.2023,

the appeals were dismissed on account of low tax effect.

12.2. From the facts of the present case and Jain Grani cnarrated above,

it is seen that the Department has kept the present case in 'Call Book' as

the issue involved in the present case are similar to the facts of Jain

Grani. The adjudication of this case was done after disposal of the Jain

Grani by the Supreme Court. Thus, the decision of the Tribunal in Jain

Grani, vby Final Order No. C/84-85/2009 (PB) dated 17.02.2009, as

upheld by the High Court of Rajasthan, is squarely applicable to the facts

and circumstances of the present case.

Observations on Demand of Customs Duty:


13. Now, as far as the demand of customs duty on imported marble is

concerned, we find that the said issue has already been been decided by

the   Tribunal in Jain Grani. The Relevant extracts of the order of the

Tribunal dated 17.09.2009, with respect to the demand of customs duty

are reproduced below for ready reference:-


      " 3.   ---The finished goods to be exported as per LOP were         -

      "marble slabs/ tiles and Granite tiles". In December, 2003 it was

      expanded to include " -Serpentine slabs/ tiles, dressed Serpentine

      blocks and dressed marble blocks"--Thus, while their imports were
                                                       25
                                                                          C/51057/2025
exclusively of white marble blocks and the DTA clearances were of

marble slabs/tiles and dressed marble block made out of the

imported marble blocks, their exports, except for one small

consignment       of   slabs/tiles    of    marble/     granite      made     out   of

indigenous marble/ granite blocks, were of dressed blocks, slabs

and tiles    of   serpentine,        made    out   of      domestically     procured

serpentine blocks. ---


4.1.1 We do not agree with the contention that the marble and

Serpentine Stone are similar in view of the following-


----

4.1.2 Since except for the name- Green marble used for Serpentine stone, there is nothing in common between marble and Serpentine, and since the domestically procured Serpentine stone ( on which there is no central excise duty) is much cheaper than the imported marble blocks (imported duty free) and thus the dressed white marble blocks and the dressed blocks, slabs and tiles made out of domestically processed serpentine stone are just not comparable in any respect, the export obligation against the duty free import of white marble blocks cannot be met either by export of dressed Serpentine block and Serpentine slabs/ tiles, made out of domestically procured Serpentine or by using the imported white marble blocks for making dressed blocks, slabs or tiles for domestic sale within the DTA quota, even if as per the LOP, the basket of finished products for export comprises of dressed marble blocks and marble slabs/ tiles as well as dressed Serpentine blocks and Serpentine slabs/ tiles. DGFTS circular dated 10.06.2002 is of no persuasive value as after reference to DGFT from the CBEC in 26 C/51057/2025 respect of this circular, the DGFT itself has prescribed separate input-output norms for dressed Serpentine blocks/ Serpentine slabs/ tiles in the SION. From the CBEC circular No. 12/08-Cus dated 24.07.2008 explaining the provisions of the 2004-2009 EXIM policy ( para 8 of the circular), it is clear that he goods sold by an EOU into DTA must be 'similar 'to the goods exported, within the meaning of the term 'similar 'as defined in the Board's circular No. 07/2006-Cus dated 13.01.06 and in the case of a multi product 100% EOU manufacturing say, product A and B, it is not open to the unit to exclusively export the product A and keep the product B exclusively for DTA sale, unless the product A and B are similar. In fact, as per the EXIM policy 2004-2009, a 100% EOU manufacturing products A and B for export, can sell into DTA one product, say A, upto 75% of its FOB value of exports, within the overall DTA sale entitlement. The idea behind this condition is to prevent the misuse of 100% EOU scheme by duty free import of costly material for use exclusively in the manufacture of finished goods for DTA sale and meeting the export obligation by exporting the finished goods made out of domestically procured cheap material. In this case, since the export of dressed marble blocks, marble slabs & tiles made out of imported white marble blocks is almost nil, the appellant company could not sell the products made out of imported white marble blocks unit into DTA against the DTA entitlement earned by export of dressed blocks, slabs and tiles of serpentine stone and the DTA sale of the appellant company cannot be counted towards their export obligation.

4.1.3 In view of the above discussion, we hold that the condition for duty free import by a 100% EOU, as prescribed in the notification 27 C/51057/2025 No. 52/03-Cus has not been fulfilled in respect of imported marble blocks and, therefore, the same are not eligible for duty exemption, and since these marble blocks, after their use have not been used for the intended purpose, the same would be liable for confiscation under Section 111(o) of the Customs Act, 1962. ---"

(Emphasis supplied) 13.1. These findings have been upheld by the High Court of Rajasthan in the appeal filed by Jain Grani, by order dated 21.02.25. Accordingly, the appellant is not eligible for the exemption provided under the Notification Nos. 53/97- Cus. dated 03.06.1997 and 52/2003-Cus. dated 31.03.2003 and it is liable to pay the customs duty on the imported marble blocks. 13.2. The appellants have not suppressed any information regarding imports/ procurement and exports/ clearance from the authorities. They have been filing ER-1 returns regularly containing all necessary details of activities undertaken by it. Further, the packages/ containers for export were examined and certified by the jurisdictional central excise officers. Further, the Marble Slabs/ Tiles were cleared into DTA pursuant to obtaining permission from the Development Commissioner. Since the facts pertaining to the transactions undertaken by the Appellant were within the knowledge of the department, it is held that the extended period of limitation cannot be invoked. It is also pertinent to note that in Jain Grani, the Tribunal had, under similar circumstances, held that the company could not be accused of suppression of facts with intent to evade the payment of duty and therefore recovery of duty on imported marble blocks, would be restricted only to the normal limitation period alone. The relevant observations made by the Tribunal in this regard in Jain Grani are as under: -
28
C/51057/2025 "6. The next point of dispute is as to whether the proviso to Section 28(1) of the Customs Act is invokable for demand of customs duty on the imported marble blocks and whether the appellant company is liable for penalty under Section 114A of the Customs Act. The Commissioner has held the Appellants to be guilty of suppression of facts with intention to evade the payment of duty on the grounds that -
(a) periodical ER-2 returns filed by the Appellant company did not show the details of the clearances made for export under bond of the dressed blocks/slabs/tiles manufactured of imported marble stone and indigenously procured serpentine stone and from these returns, it could not be made out as to whether the Appellant company was exporting only the dressed blocks, slabs and tiles of the indigenously procured serpentine blocks and this could be ascertained only after surprise visit to the factory and inquiry from Shri Mukesh Modi; and
(b) the DTA invoices of the Appellant company invariably used the description - "Marble slabs" in the column of "description of the goods cleared", from which it could not be ascertained as to what kind of goods were being cleared by the Appellant.

The Appellant's contention, on the other hand, is that the Departmental officers were aware of the fact that while dressed serpentine blocks, Serpentine slabs/tiles made out of domestically procured serpentine blocks were exported and the dressed blocks, slabs and tiles made out of imported marble blocks were cleared to DTA, in view of the facts that -

(a) all exports were factory stuffed under supervision of the jurisdictional Central Excise Officers and the export documents have been certified by the central excise officers ; and 29 C/51057/2025
(b) the Appellants vide letter dated 29-7-03 to the Assistant Commissioner clearly mentioning that they are manufacturing marble slabs/tiles and clearing the same to DTA, had asked for correct rate of central excise duty on the DTA clearances.

6.1 The LOP issued to the Appellant company and its amendments issued by the Development Commissioner from time to time and copies of which were also endorsed to the jurisdictional Assistant Commissioner, mentioned in addition to dressed marble blocks, marble slabs and marble tiles, the dressed serpentine blocks/serpentine slabs/tiles and other slabs/tiles of other stones also, as the Appellant company's finished products for export. Since all the exports were under Central Excise supervision, the jurisdictional Central Excise Officers could not be unaware of the fact that except for one small consignment of marble slabs and granite slabs, all exports of the Appellant company were of dressed serpentine blocks/serpentine slabs/tiles. Appellant's letter dated 27-7-03 to the Assistant Commissioner indicates that the Departmental officers were also aware of DTA clearances of the marble slabs/tiles. In case of a 100% EOU, the jurisdictional range officer invariably gets intimation about the receipt of duty free imported goods or domestically procured goods and the confirms the receipt of the same in the EOU to the concerned Customs house/Central Excise range and therefore the jurisdictional central excise officer cannot be unaware of the fact that while the Appellants are importing marble blocks and domestically procuring serpentine blocks, they are exporting only the dressed serpentine blocks and serpentine slabs/tiles and cleaning dressed marble blocks and marble slabs/tiles to DTA. In view of this we hold that the Appellant company cannot be accused of suppression of facts with intent to evade the payment of duty and therefore for recovery of duty on imported marble 30 C/51057/2025 blocks, only the normal limitation period under Section 28(1) would be available and the penal provisions of Section 114A of the Customs Act would not be attracted. ....."

(Emphasis supplied) 13.3. Thus, by following the ratio of the decision of the Tribunal in Jain Grani that the demand of customs duty confirmed in the impugned order is upheld, only for the normal period of limitation and consequently, the demand confirmed in the impugned order by invoking the extended period of limitation is set aside.

13.4. On this score, we also find that the learned Adjudicating authority has inter alia ordered to demand Customs duty under proviso to Section 28(1) read with B-17 bond furnished by the Appellant. It is a settled principle of law that demand can be raised for extended period only when the ingredients mentioned therein are present. The Bond executed by the appellant cannot be invoked to demand duty for extended period. In support of this view, we rely on the decision of the Tribunal in Commissioner of C. Ex., Pune-I vs. Emcure Pharmaceuticals Ltd, 2014 (307) E.L.T. 180 (Tri. - Mumbai), wherein it was held that merely because the assessee executed a B-17 bond they would not fall outside the purview of Section 11A. The said decision was also affirmed by the Bombay High Court in Commissioner of C. Ex., Pune-I vs. Emcure Pharmaceuticals Ltd, 2016 (342) E.L.T. 172 (Bom). The relevant observations of the Tribunal, Mumbai in the aforesaid decision are reproduced below: -

"5. We have carefully considered the submissions made by both the sides. From the records it is clearly seen that the respondent had declared to the department that they would be availing the benefit of Notification 31 C/51057/2025 23/2003 in respect of advance DTA sales to be effected by them in terms of the permission granted by the Development Commissioner as early as in 2004 itself. Therefore, the respondent cannot be, said to have withheld any information from the department. The respondent's plea that they were entitled for the benefit of exemption under Notification 23/2003 under the belief that they were entitled for benefit of such Notification cannot be said to be a mis-declaration as held by the Hon'ble Apex Court in Northern Plastics Ltd. v. Collector of Customs & Central Excise - AIR 1998 SC 2371 = 1998 (101) E.L.T. 549 (S.C.). If the department felt that the respondent was not entitled to such exemption, they should have issued the show cause notice within the period stipulated under Section 11A. Revenue's reliance on the decision of the Tribunal in the case of Endress + Hauser Flowtec (I) Pvt. Ltd. (supra) does not come to their rescue for the reason that B-17 bonds are executed not only by the 100% EOUs but also units in the DTA. If Section 11A is applicable in respect of units in DTA who have executed B-17 bonds before the department, the same logic would apply in respect of 100% EOUs as well. Therefore, the argument that merely because the respondent has executed a B-17 bond they would fall outside the purview of Section 11A is illogical and irrational. One cannot interpret the law in such a way so as to make the provisions of law redundant."

13.4.1. Thus, we hold that when the relevant facts about the activities undertaken by the Appellant were within the knowledge of the Department, duty cannot be demanded for extended period of limitation, by invoking the B-17 bond. Thus, we restrict the demand of customs duty for the normal period of limitation.

32

C/51057/2025 Observations on Demand of Excise Duty:

14. Regarding the demand of central excise duty confirmed in the impugned order, we find that that the appellant, M/s. Abhishek Exports, have under taken the process of cutting the marble blocks. As per chapter Note 6 to Central Excise Tariff, in relation to products of CTH 2515 (marble etc) and 2516 (granite etc), the process of cutting or sawing or sizing or any other process, for converting of stone blocks into slabs or tiles shall not amount to 'manufacture' during the relevant period. Thus, the process of cutting the marbles into marble slabs/tiles undertaken by the appellant on the imported marble blocks does not amount to 'manufacture' as defined under Section 2(f) of the Central Excise Act, 1944. The Tribunal in Jain Grani has categorically held that the process of cutting, sawing or sizing under taken be the appellant does not amount to 'manufacture' and the decision has attained finality. The relevant extracts of decision dated 17.09.2009 of the Tribunal in Jain Grani with respect to the demand of central excise duty is as under:

"5. Next point of dispute is as to whether the DTA clearances of the Dressed marble blocks and marble slabs/tiles would be eligible for concessional rate of duty under notification No. 23/03-CE. In this regard, the contention of the Appellants is that since during the period of dispute, as per the Hon'ble Supreme Court's judgements in case of Aman Marble P. Ltd. vs CCE and CCE vs Fine Marble & Mineral Pvt. Ltd. and the judgement of this Tribunal in cases of Associate Stone Industries (Kotah) Ltd. vs CCE, Kotah Stones Pvt. Ltd. vs CCE and Tirupati Granite P. Ltd. vs CCE, cutting of marble blocks into slabs or tiles did not amount to manufacture, in any case, no central excise duty can be charged in respect of DTA clearances of dressed marble blocks and marble slabs/ tiles and in 33 C/51057/2025 respect of these clearances, as per the provisions of the 1st proviso to para 3 of the notification No. 52/03-Cus, only the customs duty on the imported marble blocks used for production of dressed marble blocks and marble slabs/tiles can be charged. We agree with this contention of the Appellants, as we find that during the period of dispute, there was no chapter note in chapter 25 or the central excise tariff, providing that the process of cutting or sawing or sizing or polishing or any other process for converting stone blocks into slabs or tiles shall amount to manufacture and such a chapter note was introduced only w.e.f. 01.03.2006 and therefore, during the period of dispute, in view of the above-mentioned judgements of Hon'ble Supreme Court and the Tribunal, no central excise duty could be charged in respect of these DTA clearances and only customs duty in terms of 1st proviso to para 3 of the notification 52/03-Cus could be charged on the imported marble blocks used for making dressed marble blocks and marble slabs/ tiles and this duty, as discussed in the earlier in para 4.1.3 above is, in any case, chargeable. We do not agree with the Commissioner's finding that the definition of 'manufacture 'in Section 2(f) of the Central Excise Act and the above-mentioned judgements of Hon'ble Supreme Court are not applicable to 100% EOU for which the term 'manufacture 'as defined in Exim Policy is applicable and for this reason, the DTA clearances of dressed marble blocks and marble slabs/ tiles would attract central excise duty as-
(a) the definition of "manufacture" as given in the EXIM policy is relevant only for the purpose of duty free import of inputs and capital goods under customs notification no. 52/03-Cus and its predecessor notification and excise duty free domestic procurement 34 C/51057/2025 of indigenously manufactured inputs or capital goods for use in or in relation to "manufacture" (as defined in EXIM policy) of the finished goods; and
(b) the DTA clearance attract central excise duty only under the proviso to Section 3 (1) of the Central Excise Act which would be attracted only if the activity of the EOU is "manufacture" within the meaning of this term as defined under Section 2(f) of the Act and as interpreted by various judgements of Hon'ble Supreme Court."

(Emphasis supplied) 14.1. The ratio of the said decision cited supra is squarely applicable to the facts and circumstances of the present case.

14.2. The learned Special Counsel representing the Revenue tried to make a distinction between the definition of 'manufacture' available under section 2(f) of the Central Excise Act for the domestic units and the 100% EOU. He submitted that the EOU Scheme now encompasses activities such as packaging, processing and rendering services which in strict terms are not termed as 'manufacture' but a broader meaning of manufacture as given in Exim policy/ FTP is to be taken in respect of goods manufactured or produced in a 100% EOU and cleared into DTA. It is not possible to agree with the submission made by the learned Special Counsel of the Revenue. The activity of 'manufacture' does make any distinction between a unit located in the domestic tariff area and a 100% EOU.

14.3. Thus, by relying on the decision of the Tribunal in Jain Grani, it is held that the process of cutting the marbles into marble slabs/tiles undertaken by the appellant on the imported marble blocks in this case, 35 C/51057/2025 does not amount to 'manufacture' as defined under Section 2(f) of the Central Excise Act. Accordingly, we hold that no central excise duty is payable by the appellant on the clearances effected to the Domestic Tariff Area.

15. The appellants have prayed for adjustment of the central excise duty already paid by them at the time of DTA clearance of the marble slabs against the demand of custom duty, if any, confirmed for the normal period of limitation. The learned Special Counsel for the Revenue opposed the above prayer and argued that during the relevant period there were many decisions holding the view that the process of cutting marble blocks into slabs/tiles does not amount to 'manufacture' but despite these decisions, the appellants were paying excise duty at concessional rate for their DTA clearance without any demur. The learned Special Counsel cited the decision of the Supreme Court in Mafatlal Industries and argued that if an assessee pays the duty based on a wrong understanding, he is still governed by the Refund provisions of the Act. Accordingly, the learned Special Counsel for the Revenue has contended before us that adjustment is not permissible and the appellant has to follow the refund route only.

15.1. In this regard, the records have been perused. It is found that the issue whether cutting of marble blocks amounts to 'manufacture' or not was under dispute and the issue was pending before various forums. The appellant genuinely believed that the activity of cutting or sawing of marble blocks into slabs/tiles amounts to 'manufacture' as defined under section 2(f) of the Central Excise Act, 1944 and discharged duty liability at the time of clearance of goods to the DTA. The Department also did not objected to the central excise duty paid by the appellant on the goods cleared to the DTA. Thus the duty paid by the appellant for the clearances 36 C/51057/2025 made to DTA cannot be considered as duty paid on account of wrong understanding. Thus, the decision of the Supreme Court in Mafatlal Industries cited by the learned Special Counsel of the Revenue is not applicable to the facts and circumstances of the present case. 15.2. The appellant has relied on various decisions in support of their claim that the central excise duty paid by the during DTA clearance can be adjusted against the customs liability liable to be confirmed. In the case of Nikhil Industries, the Tribunal has held that duty already paid by the EOU on the finished goods was adjustable against the duty leviable on the raw materials. The relevant part of the said decision is reproduced below for ready reference:

"5. We have considered the submissions of both the sides. The undisputed facts are that the Appellants were granted letter of permission for manufacture and export of finished goods and they had accepted the terms and conditions and executed legal agreement also in terms of EXIM Policy. It is also not disputed that they have not exported any goods out of the raw material imported by them or by suing the capital goods procured indigenously without payment of duty. In view of these undisputed facts the Appellants are liable to discharge the duty liability, both in respect of goods imported by them and the capital goods procured by them indigenously. While discharging the Customs duty liability on the imported raw material the duty of Customs already discharged by them in respect of raw material removed in D.T.A. has to be adjusted. Similarly the duty paid by them while removing the finished goods made out of the imported raw material has to be adjusted against the Customs duty liability since the duty is now upheld in respect of entire raw material imported by them. We agree with the learned SDR that no depreciation has to be granted to the Appellants while levying the duty on the capital 37 C/51057/2025 goods since the same have not been used for the purpose they were procured free of duty i.e. manufacture of goods in a 100% E.O.U. for the purpose of export. We, therefore, uphold the demand of Central Excise duty. We also uphold the demand of Customs duty subject to the adjustment of duty already paid by the Appellants on the removal of raw material as such and on the removal of finished goods manufactured out of the raw material imported by them. Penalty is also imposable on the Appellants as they have not fulfilled the export obligation. However, taking into consideration the facts and circumstances of the case we reduce the penalty to Rs. 1 lakh. The appeal is disposed of in the above terms."

15.3. We find that the Tribunal in South Asian Petrochem Ltd held that duty paid in excess under one head can be adjusted against duty short paid under a different head, insofar as the duties are paid to the Central Government. The relevant part of the said decision is reproduced below for ready reference:

"2. We find that the appellants have short paid Central Excise duty to the extent of Rs. 78,51,694/- and they have made excess payment towards education cess to the extent of Rs. 1,03,52,860/-. These payments are not controverted in the impugned order. We find that in para 16 of the impugned order, the jurisdictional Commissioner says that he is not convinced that the short payment can be adjusted against the excess payment. The learned Advocate appearing for the appellants confirms that the jurisdictional Commissioner is in-charge of the appellants' export oriented unit, and both Customs & Excise work is handled by the same Commissioner. As such, we find no reason why the same authority, who is in-charge of both the Excise & Customs work relating to the appellants' Unit, cannot order an adjustment in the payments, which have already been made. After all, the amounts have 38 C/51057/2025 been paid to the Central Government under different heads and as explained by the learned Advocate appearing for the appellants, wrong payments were made for want of clarity regarding calculation of educational cess, which was clarified by the Board later on.
3. Considering the entire facts and circumstances of the case, we direct the jurisdictional Commissioner to make adjustment between the short payment and excess payment made by the appellants. As regards the balance amount after adjustment, the same may be considered for refund provided the appellants prefer a refund claim as required under the law."

15.4. We find that the above decision was affirmed by the Hon'ble Calcutta High Court in Commissioner vs. South Asian Petrochem Ltd, 2009 (233) E.L.T. A133 (Cal.).

15.5. Thus, in view of the aforesaid, it has been held that central excise duty paid by the appellant for the DTA clearance of marble slabs can be adjusted against the customs duty liability, if any, confirmed for the normal period of limitation.

16. Regarding confiscation of marble blocks and imposition of redemption fine, it is the provisions of Section 111(d) and 111(o) of the Customs Act have to be examined. These provisions are not invokable as regards the Marble Blocks inasmuch as neither their import is prohibited, nor has there been any non-observance of any condition surrounding their import. Further, the Marble Blocks are not liable to confiscation because they have been converted into Marble Slabs/Tiles and also cleared into DTA. They are no longer physically available. In the case of M/s. Mahindra Aerostructures Pvt. Ltd. and M/s. Tangirala Subrahmanya Sarma, DGM vs. Commissioner of Customs, Chennai, Final Order Nos. 40472 & 40473/2025 dated 24.04.2025, it has been held that for 39 C/51057/2025 confiscation of goods, both liability and availability of the goods are necessary. Further, in the own case of the appellanrt in Abhishek Exports & Ors. vs. Commissioner of Customs, Jodhpur Headquarters, Jaipur, Final Order Nos. 50325-50334/2026 dated 09.03.2026, the Tribunal held that Marble Blocks are not liable to confiscation under Sections 111(d) and (o) of the Customs Act since their import was neither prohibited nor was any import condition violated. Thus, as the marble blocks had been already used in the manufacture of Marble Slabs/Tiles and not available, the same cannot be held liable to confiscation. Therefore, the order of confiscation of the said goods is set aside. As the Marble Blocks are not liable for confiscation, redemption fine is not imposable. Thus the redemption fine imposed under Section 125 of the Customs Act is also set aside.

17. Regarding the penalties imposed on various appellants, it is seen that the relevant facts about the activities undertaken by the appellants were within the knowledge of the department. The appellants have not suppressed any information regarding imports/ procurement and exports/clearance from the authorities. They have been filing ER-1 returns regularly containing all necessary details of activities undertaken by it. Further, the packages/ containers for export were examined and certified by the jurisdictional Central Excise Officers. The Marble Slabs/Tiles were cleared into DTA pursuant to obtaining permission from the Development Commissioner. Since the facts pertaining to the transactions undertaken by the appellants were within the knowledge of the department, it is held that suppression of facts with intention to evade the tax are not established in this case. Accordingly, no penalty is imposable on the appellants. Consequently, all the penalties imposed against various appellants herein in the impugned order are set aside. 40

C/51057/2025

18. In view of the above findings, we pass the following order:

(I) The demand of customs duty confirmed in the impugned order, for the normal period of limitation is upheld but the demand of customs duty confirmed in the impugned order by invoking the extended period of limitation is set aside.
(II) The central excise duty confirmed in the impugned order is set aside.
(III) The central excise duty paid by the appellant for the DTA clearance of marble slabs can be adjusted against the customs duty liability, if any, confirmed for the normal period of limitation. (IV) The order of confiscation of marble blocks as ordered in the impugned order is set aside. Consequently, the redemption fine imposed under Section 125 of the Customs Act also stands set aside.
(V) We set aside all the penalties imposed on the appellants in the impugned order.

19. The appeals filed by the appellants herein are allowed to the extent indicated.

(Order pronounced in the open court on 18.05.2026) (JUSTICE DILIP GUPTA) PRESIDENT (K ANPAZHAKAN) MEMBER (TECHNICAL) Apoorva