Recovery letters for confirmed excise demand are not separately appealable, and interest follows the principal liability.

Letters issued only to aid recovery of a confirmed central excise demand were treated as part of the statutory recovery machinery and not as independent adjudicatory orders, so they were not appealable. Once the duty demand had been confirmed and had attained finality, interest was recoverable as an incident of that principal liability. The Tribunal held that no separate show-cause notice or distinct proceeding was required for recovery of such interest, and the challenge to the recovery letters and interest demand therefore failed.

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Issues: Whether letters issued in aid of recovery of a confirmed central excise demand were appealable or otherwise open to challenge, and whether interest on the confirmed demand could be recovered without separate proceedings.

Analysis: The demand of excise duty had already been confirmed and upheld, and had therefore attained finality. The challenged letters were only communications relating to recovery action taken on the basis of that final demand. Such recovery steps were held to be part of the statutory recovery machinery and not an independent adjudicatory order amenable to appeal. On interest, the Tribunal held that once the duty demand stands confirmed, interest is statutorily recoverable as an incident of the principal demand. Interest was treated as running with the duty liability, and no separate show-cause notice or distinct proceeding was considered necessary for its recovery.

Conclusion: The recovery letters were not appealable, the interest demand was valid as a consequence of the confirmed duty demand, and the appeal was unsustainable.

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