Gujarat State Fertilizers & Chemicals ... vs Vadodara-I on 3 December, 2025
Appeal No. E/12167/2019
5.1 We find that the decision of Hon'ble High Court of Judicature of
Madhya Pradesh at Gwalior in the case of Principal Commissioner of CGST &
C. Ex., Headquarters Bhopal vs. Godrej Consumer products Limited (supra)
has discussed this issue in detail. It held that overall duty liability/ short
payment should be arrived at after considering the duty already paid during
that year on such goods. It also held that adjustment of short/ excess paid
duty is permissible against demand determined based on annual costing.