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    <title>2019 (9) TMI 396 - CESTAT AHMEDABAD</title>
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    <description>Penalty under the Cenvat Credit Rules could not be sustained against a person who only acted as a mediator and did not avail credit, because liability attached to the person who actually took the credit. Penalty under the Central Excise Rules was also unsustainable where the persons were neither manufacturers nor exporters and no relevant contravention was established. Penalty under the Customs Act similarly failed because no import or export involvement or customs contravention was shown. Relief beyond the scope of the show cause notice was impermissible, so the Revenue could not obtain enlarged relief on appeal.</description>
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      <description>Penalty under the Cenvat Credit Rules could not be sustained against a person who only acted as a mediator and did not avail credit, because liability attached to the person who actually took the credit. Penalty under the Central Excise Rules was also unsustainable where the persons were neither manufacturers nor exporters and no relevant contravention was established. Penalty under the Customs Act similarly failed because no import or export involvement or customs contravention was shown. Relief beyond the scope of the show cause notice was impermissible, so the Revenue could not obtain enlarged relief on appeal.</description>
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