Clubbing of clearances requires notice to each unit and proof of common manufacture before adverse excise treatment applies.

Clearances of two units could not be clubbed for central excise purposes where the show cause notice was issued only to one unit and no notice was served on the other unit whose clearances were also proposed to be added. Such action breached natural justice because adverse consequences cannot be imposed without informing the affected assessee of the alleged acts or omissions. The appellate finding that the Revenue had not established that both units belonged to one manufacturer also remained unchallenged, so the attempt to club the clearances failed on the facts.

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Issues: Whether the Revenue could club the clearances of two units for central excise purposes without issuing a show cause notice to the other unit and without establishing that both units were of one manufacturer.

Analysis: The record showed that the show cause notice had been issued only to one unit, while no notice was issued to the other unit whose clearances were sought to be clubbed. Such clubbing without notice offended the principles of natural justice, since an assessee must be informed of the alleged acts or omissions before adverse consequences are imposed. The finding of the appellate authority that the Revenue had also failed to prove that both units belonged to one manufacturer remained uncontroverted.

Conclusion: The clubbing of clearances was not permissible on the facts, and the Revenue's challenge failed.

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