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    <title>2022 (4) TMI 476 - CESTAT MUMBAI</title>
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    <description>Allegations of clandestine manufacture and removal of MS ingots based on electricity consumption norms, technical opinion, an outdated article, and third-party records were not supported by cogent evidence. The consumption norm adopted by Revenue was found unreliable because power use varied with operational factors and ancillary consumption was not accounted for. The technical opinion was not shown to be an authoritative institutional report, and the weighbridge and transporter statements were uncorroborated with cross-examination denied. In the absence of evidence of extra raw material, unaccounted transport, buyers, flow-back of funds, or statutory record discrepancies, the duty demand and penalties could not be sustained.</description>
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      <description>Allegations of clandestine manufacture and removal of MS ingots based on electricity consumption norms, technical opinion, an outdated article, and third-party records were not supported by cogent evidence. The consumption norm adopted by Revenue was found unreliable because power use varied with operational factors and ancillary consumption was not accounted for. The technical opinion was not shown to be an authoritative institutional report, and the weighbridge and transporter statements were uncorroborated with cross-examination denied. In the absence of evidence of extra raw material, unaccounted transport, buyers, flow-back of funds, or statutory record discrepancies, the duty demand and penalties could not be sustained.</description>
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