2000 (10) TMI 327

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....he Respondents. [Order per : S.S. Sekhon, Member (T)]. - This appeal is against a finding of the Commissioner (Appeals) as recorded in paras 6 and 7 which is extracted herein below : "6. The whole issue therefore, boils down to whether ingots are re-rollable material at all. The answer has to be only in the affirmative. The appellants even before these amendments have come into being....

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....ble material find expression for the first time under Notification No. 53/92 only. If someone were to argue that under Notification No. 33/92 even rollable material is covered perhaps one is wrong. Words and expressions in notifications have to be construed as they exist, and no implied meanings can be given to words used in a notifications. If that is the case is one right in implying that Notifi....

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....ording to them ingots are fully covered by generic expression re-rollable material which is the classifying input mentioned in Col. 2(a) of the Table appended to Notification No. 33/92. They further argued that when duty paid ingots are used in the manufacture of bars and rods no duty liability on the final product could arise as in such a case it amounts to double taxation and that is the reason ....

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....) for ingots are also covered under re-rollable is not acceptable. 2. We have heard ld. DR Shri M. Murugan for the department who has reiterated the grounds made in the appeal. 3. None appeared for the respondents. 4. We have considered the submissions and the material on record and find that - (a)  The Order-in-Appeal is a well reasoned and self-explanatory order e....