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Indian Drugs Manufacturers ... vs Union Of India on 22 December, 2011

If the intention was not to restrict the applicability of Rule 8 to cases where the entire production was being captively consumed, the Rule would have simply stated "where excisable goods are consumed by an assessee himself or on his behalf in the 8 Excise Appeal No. 75474-75475 of 2014 manufacture of other articles" instead of preceding the above expression with the words "where the excisable goods are not sold". This view is also supported by the judgment of the jurisdictional High Court in the case of Indian Drug Manufacturers Association v. Union of India, wherein the Court held that Rule 8 applies in a situation where goods are not sold but are cleared „exclusively‟ to be used in consumption or for manufacture of other articles. We also agree with the contention of the assessee that Rule 8 will apply only in two situations, (a) where the goods are consumed by him in the same factory (captive consumption) or (b) where such goods are transferred to another factory for consumption in the manufacture of other articles on behalf of the assessee. In this case, it is not the case of the revenue that the goods were transferred to other units for manufacture of other articles on behalf of the assessee/appellant, i.e. the Dolvi Unit. We agree with the assessee‟s contention that the expression „assessee‟, wherever it appears in the Central Excise Rules, applies to a particular factory, which is why different units belonging to one company are separately registered and separately assessed to duty. Since the assessee in the present case is the Dolvi plant and it is not the revenue‟s case that the other three units of the company to whom HR coils were transferred were undertaking further manufacturing operations on behalf of the Dolvi Unit, the provisions of Rule 8 will not apply. We, therefore, hold that Rule 8 is inapplicable in the instant case.
Bombay High Court Cites 39 - Cited by 6 - R M Savant - Full Document

Commissioner Of Central Gst And Central ... vs Krishi Rasayan Exports Pvt. Ltd on 11 May, 2021

In support of the stand the learned Advocate places reliance on the 4 Excise Appeal No. 75474-75475 of 2014 observations of the Hon'ble High Court of Jammu & Kashmir, in the case of Commissioner of CGST & Central Excise, Vs. Krishi Rasayan Exports Pvt. Ltd., 2023 (7) TMI 661, wherein the Hon'ble High Court had categorically held that without challenging the refund sanction order, the Adjudicating Authority cannot launch proceedings under Section 11A of the Central Excise Act for recovery of the refund amount referred as erroneous payment. The relevant part of the impugned judgment is reproduced below:-
Jammu & Kashmir High Court Cites 0 - Cited by 0 - Full Document
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