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    <title>2002 (7) TMI 168 - CEGAT, MUMBAI</title>
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    <description>Rule 57AB was construed on its plain language to permit cross-utilisation of additional duty of excise credit among the specified enactments. The term &quot;said&quot; was read as referring back to all duties earlier mentioned in the rule, rather than confining credit to the same enactment from which it arose. The comparison with earlier and later provisions, which used clearer restrictive wording, confirmed that the relevant rule did not impose such a limitation. A subsequent clarification could not override the unambiguous text of the rule, and the demand, penalty, and impugned order were therefore unsustainable.</description>
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    <pubDate>Mon, 08 Jul 2002 00:00:00 +0530</pubDate>
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      <title>2002 (7) TMI 168 - CEGAT, MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=51505</link>
      <description>Rule 57AB was construed on its plain language to permit cross-utilisation of additional duty of excise credit among the specified enactments. The term &quot;said&quot; was read as referring back to all duties earlier mentioned in the rule, rather than confining credit to the same enactment from which it arose. The comparison with earlier and later provisions, which used clearer restrictive wording, confirmed that the relevant rule did not impose such a limitation. A subsequent clarification could not override the unambiguous text of the rule, and the demand, penalty, and impugned order were therefore unsustainable.</description>
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      <pubDate>Mon, 08 Jul 2002 00:00:00 +0530</pubDate>
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