Cenvat Credit Rules 6(2) & 6(3) can't impose impossible obligations or penalize for unachievable duties.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Cenvat Credit - emergence of non-dutiable goods - The provisions of Rule 6(2) read with Rule 6(3) cannot be interpreted to cast an obligation on an assessee which is impossible and thereafter penalize him for failure to discharge an impossible obligation - AT....