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Issues: Whether the Revenue had made out a case to interfere with the Commissioner (Appeals)'s order accepting the Cost Accountant's certificate and the declared landed cost for valuation of job-work manufactured medicines under Rule 173C of the Central Excise Rules, 1944.
Analysis: The appeal turned on whether the assessable value had been wrongly worked out by ignoring transportation, insurance and taxes in the landed cost of raw materials and whether the certificates produced by the assessee suffered from any verified defect. The Commissioner (Appeals) had examined multiple supplier invoices, verified the supporting material, and recorded that freight, insurance and CST had been taken into account while arriving at the landed cost. The Revenue's challenge was found to rest on assumptions, including the allegation that only one supplier's invoice had been considered, without any proper analysis of the Cost Accountant's certificate or identification of specific infirmities. The original adjudication was found to contain bare assertions without factual verification.
Conclusion: The Revenue failed to establish any ground for disturbing the Commissioner (Appeals)'s findings, and the rejection of the duty demand was upheld.
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