2018 (3) TMI 1549

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....hana Wadhwa Appellant is engaged in the manufacturing of lubricating oil under the brand name of 'Drof 8300 - 7%'. The entire production of the appellant is being cleared to their own sister unit on payment of duty on the assessable value arrived at on cost construction basis. The duty paid by them was being availed by their sister concern. It is also the fact that there is no sale of product....

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.... the invoices. Instead of reflecting the value of the final product, he showed the wrong value of raw materials. He submits that longer period cannot be made available to the Revenue inasmuch as sister unit was availing Modvat Credit and as such the entire exercise was revenue neutral. In such scenario, there can be no suppression or mis-statement with malafide intention to evade payment of duty. ....