2017 (1) TMI 1551

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....pondent Per: Anil Choudhary The issue in this appeal is whether the show-cause notice is barred by limitation. 2. Learned Counsel states that the show-cause notice dated 06.09.2005 was issued as it appeared that the fact of use of mould supplied by the customers of the appellant, non-inclusion of the cost of the said mould in the assessable value of the plastic materials so manufactured and sup....

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....ing worked out accordingly on the basis of cost of the Moulds vis a vis number of pieces guaranteed to the manufacturer. As regards justification of loading of 2%, the companys analysis of its own Balance Sheet, since 1994-95 shows that the actual tool maintenance cost works out between 1.15% to 1.38%. Hence 2% was considered sufficient to cover the cost of amortization in addition to the mainten....