2005 (3) TMI 6

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....effect from 24-7-96. The finali sation of the provisional assessment for the period from 1994-95 to 2002-2003 was ordered on 19-3-2004. In that order demand of interest was also ordered even for the period prior to 1-7-2001. The argument of the respondent is that provisions of Rule 9B of the erstwhile Central Excise Rules, 1944 with regard to provisional assessment were made applicable to Service ....

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....ce tax, can not be heard to say that provisional assessments that are continued after amendment would not attract interest provisions. This will create an anomalous situation and result in unequal treatment, which is not envis aged by the amendment. 2. The Commissioner (Appeals) has sought to give a meaning to the word 'ordered' appearing in the Supplemental Instructions issued by the Board, wh....