Apollo Tyres Ltd vs Calicut on 21 May, 2025
Ltd. Vs. CCE Belapur 2015 (315) ELT 237 (T-Mum.). In all
these decisions also on identical issue the Hon'ble Apex Court and the
Hon'ble Tribunal held that even if the activity undertaken by the appellant
Page 12 of 15
Central Excise Appeal Nos.21930,
21932, 21936-21938/2015,
20992 and 21139/2016
did not amount to manufacture but if the duty liability had been
discharged treating the activities as manufacture and such duty payment
is equivalent to or more than the credit taken, the same would amount to
non-availment of credit and consequently. no reversal of credit was
required to be made.