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b) The Panchanama as drawn is being questioned and independent material was required to be brought on record to establish the contents of the same. The non-consideration of request to visit the factory as made on various dates to the authorities show a closed mind and a desire not to take defense explanations in consideration. Orders emanating with such back ground are to be struck down.

c) documents on purchase/procurement of machinery produced have been brushed aside and not considered. Registration independently has been granted to Zenith by the Central Excise officers after enquiry and now that is being questioned, without bringing out any misdeclaration non declarations, on part of Zenith. Zenith & PEP come under the jurisdiction of the same Proper Officer of the Central Excise Range, and After accepting them to be independent, Zenith cannot be called a dummy of PEP.