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    <title>2025 (2) TMI 676 - CESTAT KOLKATA</title>
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    <description>Demands alleging clandestine manufacture and removal were found unsustainable where they rested on theoretical input-output ratios, unauthenticated printouts, diary entries, or eye estimation without tangible corroboration such as transport evidence, buyer statements, excess raw-material proof, or cash trail. Cenvat credit was not denied because receipt and use of the goods in manufacture was established and remained unrebutted. A shortage-based duty demand based only on estimated stock difference was set aside for lack of reliable verification. The consignment-agent issue was remanded for factual verification of duty already paid and cum-duty working. The extended limitation period and penalties were held inapplicable because the department already knew the facts and the substantive demands largely failed.</description>
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      <description>Demands alleging clandestine manufacture and removal were found unsustainable where they rested on theoretical input-output ratios, unauthenticated printouts, diary entries, or eye estimation without tangible corroboration such as transport evidence, buyer statements, excess raw-material proof, or cash trail. Cenvat credit was not denied because receipt and use of the goods in manufacture was established and remained unrebutted. A shortage-based duty demand based only on estimated stock difference was set aside for lack of reliable verification. The consignment-agent issue was remanded for factual verification of duty already paid and cum-duty working. The extended limitation period and penalties were held inapplicable because the department already knew the facts and the substantive demands largely failed.</description>
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