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Issues: Whether the retrospective cancellation of CT-2 certificates and consequent demand of duty on goods already received under valid licences and certificates was proper.
Analysis: The respondents had been issued a valid L-6 licence and CT-2 certificates and had procured the goods on that basis. The cancellation was sought after the goods had already been received, and the record also showed that no proper show cause notice had been issued before demanding duty. Retrospective withdrawal of the certificates after their use by the assessee was treated as an improper course of action.
Conclusion: The retrospective cancellation of the CT-2 certificates and the demand of duty on goods already received were not proper, and the Revenue's appeal was rejected.
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