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The above referred details would show that Petitioner's is an established industry, and the Petitioner has been conducting the business operations in proper manner thereby contributing to the Government exchequer to a large extent.

5. For manufacture of goods like Sponge Iron, the Petitioner has installed in the factory four Kilns, for processing raw material like Iron Ore therein. Another raw material, namely, Coal, which is in the nature of a consumable, is also used in such kilns for processing iron ore. The Petitioner has been regularly procuring by way of purchases from importers, substantial quantities of coal for manufacturing operations in the factory.

6. Prior to 1.7.2017, coal was classifiable under Heading 2701 of the Customs Tariff when imported in India, and under Heading 2701 of the Central Excise Tariff if coal was produced in India. For ready reference. extracts of Chapters 27 of the Central Excise Tariff as it stood prior to 1.7.2017 are enclosed and marked as Annexure-"C".

When iron ore and coal were processed in kilns for manufacturing goods like Sponge iron, obviously residue of coal would arise as a result of manufacturing process in the kilns; and such residue of coal also retained a very low calorific value indicating the parameter of Volatile Matter (VM), which is the capacity or capability of the product for burning and generating heat. Ordinarily, VM parameter of normal or ordinary coal is found to be in excess of 25, whereas the same parameter of VM residue of coal arising after the manufacturing process in the kiln is very low, ranging between 2 to 4, but not in excess of