Chewing Tobacco Rules permit transferring unutilized CENVAT Credit between units; revocation by the Department cannot be retroactive.

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....Transfer of CENVAT Credit lying un-utilized - the scheme contemplated under Chewing Tobacco Rules is self-contained and there is no bar under the said Rules to transfer the credit from one unit of the manufacturer to the other unit - If, at all, the Department wants to withdraw the permission, it cannot be done with retrospective effect.....