Refund Denied for Unutilized CENVAT Credit: Assessee Considered Ultimate Consumer with No Set-Off Opportunity.

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....Refund of unutilized CENVAT credit - if an assessee has CENVAT credit balance without any duty on which to apply it, such assessee is an ultimate consumer to the extent that duty or tax has been paid upto the preceding stage and there no scope for setting off of such credit - refund not allowed - AT....