Exemption and scheme benefits after statutory amendment, penalty exposure, and de-bonding consequences framed for final hearing.

The Supreme Court framed six substantive issues on the continued availability of exemption or scheme benefits after statutory amendment, including the effect of a notification under Rule 8(1), the impact of amendment to the principal Act, EPCG and EOU treatment, penalty exposure for reliance on earlier precedents, entitlement under Rule 4(5) of the Cenvat Credit Rules, and consequences of later final de-bonding. The Revenue's allegation of fraud was noted but kept open for final hearing. Parties were directed to confine arguments to the framed points and file written submissions within four weeks, with the matter listed for hearing in the first week of March 2017.

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Outcome: The questions framed for consideration were directed to be argued on a later date, with written submissions to be filed, and one connected appeal was de-tagged.

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