2007 (1) TMI 427

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....SDR, for the Respondent. [Order per : P.G. Chacko, Member (J)]. - In the impugned order, learned Commissioner has confirmed against the appellants demand of duty of over Rs. 3.3 crores in adjudication of a show-cause notice dated 26-6-2002 covering the period 1-6-1997 to 8-6-2001. The larger period of limitation has been invoked on the basis of suppression of facts found against the assessee. T....

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....ing tobacco and were getting their product manufactured in the premises of the assessee. For this and other reasons, learned Commissioner clubbed the tobacco clearances of the SSI units with those of the appellants and raised the above demand on the latter. After giving careful consideration to the submissions made by learned Counsel and learned SDR, prima facie, we have not been able to find a co....

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....t relates to a part of the period of dispute involved in the present case. Thus, it appears, the department is stopped from pleading that the 10 SSI units were working as 'dummies' of the appellant-firm. Therefore, the present demand of duty on the appellants, which is based on a premise that the 10 SSI units were only dummies of the appellant-firm, may not be sustainable in law. The appellants ha....