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Issues: Whether the respondent was entitled to refund of accumulated CENVAT credit arising from deemed exports made to 100% EOUs within India under Notification No. 5/2006.
Analysis: The issue was treated as covered by the decision of the High Court of Gujarat holding that deemed exports are to be treated at par with physical exports for the purpose of granting refund of accumulated credit under Notification No. 5/2006.
Conclusion: The respondent was not granted any further relief in these appeals, which were rejected.
Ratio Decidendi: Deemed exports to 100% EOUs are to be treated at par with physical exports for refund of accumulated credit under Notification No. 5/2006.