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Commissioner Of Central Excise, Nagpur vs M/S Ballarpur Industries Ltd on 30 August, 2007

13. It is the contention of Learned Counsel for the appellant that the demand is flawed for having traversed beyond the framework of the show cause notice in which, though inappropriateness of usage in manufacture of ineligible goods is narrated, the consequent demand proposed has not been disaggregated from the recovery of duty of ₹ 55,75,39,599 foregone on procurement of goods enumerated in the norms and ₹ 4,08,13,609 foregone on goods not included in the norms. It was further submitted that, in framing the issues purportedly contained in the notice, the adjudicating authority, of his own volition, insinuated the proposal to disentitle concessional rate of duty incorporated in paragraph 6.8 (a) of the Foreign Trade Policy (FTP) 2009-14 and reflected in notification no. 23/2003-CE dated 31st March 2003. According to him, even while holding that goods permitted for clearance on payment of duty are not excluded from being manufactured out of 'duty free' procurements in the face of proposal in the notice for recovery of 'duty foregone' to that extent, on 'raw materials' so used, the adjudication order has determined duty as arising under section 3 of Central Excise Act, 1944 which is intended for levy of impost on manufactured goods. That no adjudicating authority was authorized to transgress the boundaries of notice was, according to him, clearly enunciated by the Hon'ble Supreme Court in Commissioner of Central Excise v. Gas Authority of India Ltd [2008(232) ELT 7 (SC)], in Commissioner of Central Excise, Nagpur v. Ballarpur Industries Ltd [2007 (215) ELT 489 E/85657, 85776 & 86019-86031/2020 19 (SC)] and in Commissioner of Central Excise, Bangalore v. Brindavan Beverages (P) Ltd [2007 (213) ELT 487 (SC)] as well as by the Tribunal in Hindalco Industries Ltd v. Commissioner of Central Excise, Allahabad [2009 (248) ELT 391 (Tri-Del)].
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