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M/S Goldy Engineering Works vs Commissioner Of Central Excise & Anr. on 14 July, 2023

9. The Ld. Authorized Representative of the Revenue has mainly relied on the decision of the Hon'ble Delhi High Court in the case of M/s. Goldy Engineering Works v. Commissioner of Central Excise [(2023) 10 Centax 189 (Del.)], which has been affirmed by the Hon'ble Supreme Court as reported in 2025 (4) TMI 1186 - SC. I find that in the above case cited by the Revenue, the amount paid by the appellant was considered as duty and the provisions of Section 11B were made applicable to that deposit wherein the issue of duty paid under a mistaken notion had not been raised and not recorded in the Order passed by the Hon'ble Court, which is not the case in the present case. In the present case, the amount deposited during the course of investigation was not as a voluntary payment, but a deposit made under a mistaken notion as to their central excise duty liability, at the insistence of the Department, as specifically pointed out by the appellant, and thus, would not amount to 'duty'. Thus, I find that the facts and circumstances of the decision cited by the Revenue are distinguishable from the facts and circumstances of the case on hand.
Delhi High Court Cites 27 - Cited by 0 - Y Varma - Full Document
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