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TaxTMI 
TaxTMI 
1992 (8) TMI 203
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....30,000/- imposed as penalty on the second applicant Hindustan Lever Ltd. The aforesaid amount of duty comprises of Rs.15,99,843 for the period June 1987 to 15-5-1989 covered by a show cause notice dated 29-10-1990. The balance amount of duty is for the period 16-5-1989 to 19-3-1990. He submits that the factory sheds have been erected at site after supply of duty paid raw material purchased from Steel Authority of India Ltd. and Tata Steel by the applicant No. 2 i.e. Hindustan Lever Ltd. and supplied to Indo Fab Engineers. Fabrication and erection work has been taken at site, there has been no pre-fabrication of parts or structures or structures themselves at a place different from the erection site. Fabrication has taken place alongwith ere....
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....ctures in factory premises at site" were fabricated and then they were taken to the erection place where they have been built into structures. He submits that the contention of the ld. advocate that there is no pre-fabrication of the parts of the structures is not correct. Hence he submits that the findings of the adjudicating authority are well within the scope of the show cause notice and are based on evidence such as contract etc. He therefore submits that the applicants do not have any case so far as the merits of the issue, whether the activity undertaken by the applicants is manufacturing activity or not is concerned. On the question of limitation he submits that no doubt the department was aware of the activities of the applicants in....