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Issues: Whether the amount payable under Rule 6(3)(b) of the Cenvat Credit Rules, 2002 for exempted goods was required to be paid at the time of clearance from the factory or could be paid at the end of the month under Rule 8(1) of the Central Excise Rules, 2002.
Analysis: The relevant language of Rule 6(3)(b) was read as prescribing the amount to be paid by reference to the value of exempted final products at the time of clearance, but not as laying down a separate payment schedule. The provisions of Explanation I and Explanation II to Rule 6, together with Section 2A of the Central Excise Act, 1944, indicated that the amount could be debited through CENVAT credit and, on default, recovered with interest in a manner comparable to recovery of wrongly taken credit. In the absence of a specific payment mechanism in Rule 6(3)(b), Rule 8(1) of the Central Excise Rules, 2002 was applied to the manner of payment.
Conclusion: The amount under Rule 6(3)(b) could be paid in the manner envisaged under Rule 8(1) of the Central Excise Rules, 2002, and the Revenue's challenge failed.
Ratio Decidendi: Where a CENVAT obligation fixes the quantum payable but does not prescribe a distinct mode or time of payment, the general payment machinery under the Central Excise Rules applies, and the provision must be construed contextually rather than as an automatic immediate-payment mandate.