Briefly stated the facts of the case are that M/s BPCL, t he
Appellants, a Government of India Undertaking, are engaged, inter
alia ... behalf of OMCs and had effected high - seas - sales to BPCL
(Appellants). The Appellants had declared the Assessable Value in the
Bills of Entry
Spirit (Petrol) and HSD (Diesel) on payment
of duty to M/s BPCL and M/s HPCL during the period from March 2008 to
October ... name. However,
subsequent to the clearance of goods to buyers M/s BPCL and M/s HPCL,
in some cases they had converted the same
City &Amp; Industrial Development ... vs Commr.Service Tax- Vii Mumbai on 5 August, 2019
City &Amp; Industrial Development ... vs Commissioner Of Service Tax Mumbai-Ii on 5 August
City &Amp; Industrial Development ... vs Commr.Service Tax- Ii Mumbai on 5 August, 2019
City &Amp; Industrial Development ... vs Commr.Service Tax- Vii Mumbai on 5 August, 2019
City &Amp; Industrial Development ... vs Commissioner Of Service Tax Mumbai-Ii on 5 August
Lic Housing Finance Ltd. vs Commissioner Of Service Tax Mumbai-I on 21 August, 2019
wherein the Tribunal upheld the submission that
BPCL is a Government owned company had suppressed the
fact and therefore, just because it is wholly owned
Resolution No. P=23015/1/2001-MKT dated 08.03.2002 including
HPCL, BPCL & IBP who have been marketing transportation fuels
before this date."
Thus ... given in
(Appendix-13).
Copies of the two invoice issued by BPCL No. 6000007724 dated 29-
04-2017 (Appendix 14) and from HPCL invoice