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Yu Televentures Pvt. Ltd. vs Union Of India & Ors. on 26 July, 2017

46. We also take note of the fact that Assistant Commissioner of Customs (Refund), New Delhi vide his Order No. 322/2016 issued from F.No. VIII(E)20/Refund/ACE/156/2016 dated 18.04.2017 has sanctioned the refund of Rs. 28,48,587/- to the appellant namely, M/s. Trust Marketing on the basis of the facts, which are pari materia and the refund has also arisen after the judgement of Hon‟ble Supreme Court in the case of M/s. SRF Limited. The learned Assistant 45 C/53523/2018 Commissioner who has sanctioned the refund amount to the appellant has held that " I find that the application containing that burden cast upon them to prove that incidence of duty not passed on to the customers was successfully discharged by the fact that the amount of excess duty paid has been shown as receivable (recoverable) in their financial statement for financial year 2015-2016 that excess duty was not added to the cost of final product. Accordingly, I hold that provisions of unjust enrichment clause under section 28 of the Customs Act are not applicable to the facts of this case, hence not invokable". We have been told that the above mentioned refund orders of Assistant Commissioner (Refund) has been accepted by the Department and no appeal has been filed against the same. This very fact prove that the Department is also convinced that there is no unjust enrichment in the applicants case. The Hon‟ble Delhi High Court in its decision in the case of YU Televentures Pvt. Ltd. (supra) has held that when the Department has accepted the certificates issued from same Chartered Accountant, to allow another refund of 46 C/53523/2018 the claimant, there was no valid reason to deny the claim of same assessee in another case. The relevant extract of the above decision is reproduced below:

M/S. Hero Motocorp Ltd vs Cce, Delhi Iii on 21 July, 2014

43. Since Hon‟ble Supreme Court observations in case of Allied Photographics India Ltd. on the aspect of price, were for a specific situation and cannot generally 39 C/53523/2018 be applied in every situation as has been distinguished in case of Hero Motocorp Ltd. versus Commissioner of Customs (Import and General) reported in 2014 (302) E.L.T. 501 (Delhi). The relevant extract of same is reproduced here below :-
Custom, Excise & Service Tax Tribunal Cites 9 - Cited by 9 - Full Document

M/S. Srf Polymers Ltd vs Commissioner Of Customs, (Export), ... on 27 September, 2017

In the light of the law laid down by the Supreme Court in SRF Ltd., (supra) the Court is of the opinion that the claim in these proceedings has to succeed. A direction is issued to the respondents to process the petitioner's refund claim and pass appropriate orders having regard to the fact the petitioner had filed supporting certificates in the form of a Chartered Accountant's clarification/certificate etc. claiming that the benefit sought was not passed on to the customers. The respondents are further directed to pay the appropriate refund amount together with interest applicable till date of actual payment within three weeks from today."
Custom, Excise & Service Tax Tribunal Cites 13 - Cited by 5 - Full Document
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