2015 (10) TMI 138

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....gation and visit to the premises of HPCEL and recovery or records and verification, etc., proceedings were initiated against HPCEL on the ground that a portion of the clearance shown in the name HEC were actually cleared by them and HEC did not have manufacturing facility and it was only a trading firm and therefore, clearance shown in the name of HEC is to be added to clearances of HPECL. The reliance for this conclusion is based on the statement of Shri Jayarama Reddy who admitted that HEC was a trading firm and therefore, entire clearance was shown in the name of HPCEL. Proceedings were initiated against HPCEL and after two rounds of litigation, the matter is again before this Tribunal. 2. This time Revenue is aggrieved on the ground ....

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....fact that during the period, the depreciation cost of the machineries had been shown in the Balance Sheet which shows that the appellants have the machinery for the production of the electric control panels which requires only a compressor, drilling machine, etc. He also submits that no evidence has been brought out to show that the machinery installed in the premises of HEC is not sufficient to manufacture of electrical control panels. No evidence has been got verified to show that there is no machinery in the premises of HEC. 6. I have considered the submission made by both the sides, gone through the records and evidence available on records. First of all, I find that the investigating officers did not visit the premises of HEC which ....