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Collector Of Central Excise,Kanpur vs Flock (India) Pvt. Ltd. C-7, Panki ... on 4 August, 2000

11. The issue with regard to the effect of non-filing of an appeal against the assessment order and denial/claim of benefit arising out of such assessment at a subsequent stage is no more open for any debate, as per the well settled principle of law laid down by the Hon'ble Supreme Court in the case of Collector of Central Excise, Kanpur Vs. Flock (India) Pvt. Ltd., reported in 2000 (120) ELT 285 (S.C.). The relevant paragraph in the said judgment is quoted below:
Supreme Court of India Cites 2 - Cited by 233 - D P Mohapatra - Full Document

Titan Medical Systems Pvt. Ltd. vs Collector Of Customs on 12 November, 2002

The allegation with regard to MEIS benefits wrongly availed by the appellant does not have an independent nexus to the Customs Act, 1962 inasmuch as such scheme designed for the Merchant Exporter are dealt with under the Foreign Trade Policy (2015-2020) and Foreign Trade (Development & Regulation) Act, 1992. Thus, the administration of MEIS squarely falls within the jurisdiction of the office of the DGFT and not the Customs authorities. The division of exercise of authority between the DGFT and Customs authorities is well recognized judicially and should be respected to prevent abuse of due process of law. The Hon'ble Supreme Court in the case of Titan Medical Systems Pvt. Ltd. Vs. Collector of Customs, New Delhi, reported in 2003 (151) ELT 254 (S.C.) have held that if the license issuing authority i.e. DGFT has not questioned the veracity of the transactions undertaken under the license, the 11 Customs Appeal No. 85078 of 2019 customs authorities cannot refuse exemption on an allegation that there was any misrepresentation. It has also been held that if there was any misrepresentation, then it was the licensing authority which had to take steps to cancel the license. In the case in hand, the adjudicating authority has only referred to the DGFT Public Notice No. 30/2015-2020 dated 08.09.2016 to hypothetically conclude without any corroboration that the actual user condition has not been fulfilled and accordingly, the appellant is liable to pay the Customs duty. For arriving at such conclusion, the learned adjudicating authority has not discussed the issue with the licensing authorities, who are competent under the Licensing Policy to discover such wrongdoing, if any. Hence, it is evident that the Department has not brought on any credible evidence to prove that the appellant had indulged into fraudulent activities with the intent to defraud the Government revenue.
Supreme Court of India Cites 7 - Cited by 40 - Full Document

Union Of India vs Ashok Kumar Sharma on 28 August, 2020

In this context, the Hon'ble Supreme Court in the case of Union of India Vs. Ashok Kumar & Ors., reported in (2005) 8 SCC 760 have held that burden of establishing malafides is very heavy on the person who alleges it; that the allegations of malafides are often more easily made than proved, and the very seriousness of such allegations demand proof of high order of credibility.
Supreme Court of India Cites 216 - Cited by 77 - K Joseph - Full Document

Shabina Abraham & Ors vs Collector Of Central Excise & Customs on 29 July, 2015

In the case of Shabina Abraham (supra), the Hon'ble Supreme Court have held that "in interpreting a taxing statute, equitable consideration are entirely out of place and it cannot be interpreted on presumptions or assumptions; the taxing statute is to be interpreted in the light of what is expressly expressed and provisions cannot be imported so as to supply any assumed deficiency."
Supreme Court of India Cites 56 - Cited by 40 - R F Nariman - Full Document
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