2014 (7) TMI 499

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....o its sister units and depots of such units during the period December 2006 to March 2011 and during the period April, 2011 to December, 2011 respectively. 2. The appellant situated at 5th KM Mile Stone, Masuri-Gulaothi Road, Tehsil Hapur, District Ghaziabad registered under Central Excise law vide Registration No. AAACH3005MXMo29, was engaged in the manufacture of aerated water and packaged mineral water falling under Chapter SH No. 22021010 and 22011020 respectively of the first schedule to the Central Excise Tariff Act, 1985. 3. During the course of audit of the records of the Appellant it was observed that the appellant was discharging the Service Tax liability against GTA on freight (inward/outward) incurred for transportation of fin....

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....llant was for internal control purposes and to measure the efficiency of the operation from economic stand point of view. 5. Revenue supported adjudication on following grounds:     (a) It is a case of stock transfer where the goods have been transferred from the factory of the appellant at Hapur to its sister unit at Varanasi and/or sister unit's depot thereat.     (b) Sister manufacturing units are different units being registered under the Central Excise Act, 1944 under different Registration number and are different assesses.     (c) The 'place of removal' cannot be equated with the place of sister unit at Varanasi. 6. Heard both sides and perused the record. 7. The crucial ....