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Issues: Whether abatement of excise duty under Rule 96ZO(2) of the Central Excise Rules, 1944 could be claimed on the basis of substantial compliance despite non-compliance with the prescribed conditions.
Analysis: Abatement under the compounded levy scheme was available only if the conditions prescribed by Rule 96ZO(2) were satisfied. The assessee failed to furnish the required information regarding finished goods and raw material on the date of closure, which was a necessary condition for relief. The contention that meter reading could not be supplied because the meter was sealed did not cure the non-compliance with the mandatory requirements.
Conclusion: The claim for abatement was rightly rejected, and the questions were answered against the assessee and in favour of the revenue.