2019 (11) TMI 1059

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....of the Learned Chartered Accountant is that the Appellate Authority has relied on the Chartered Engineer's Certificate dated 14-03-2014 certifying usage of steel of 1434.190 ton in different shape and sizes in Plant and Machinery along with entire unit installation but has discarded the same stating that the mention of tonnage of steel cannot be equated with the monetary amount of confirmed amount of demand and that the certificate did not provide that the said steel items were not used in the laying of foundation or making of structure for support of plant/machinery. In this regard, the Ld. C. A. has submitted that there is no dispute that the said steel items were used for fabrication/manufacture of plant and machinery. Further, he also r....

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....on behalf of the Revenue re-iterated the findings of the Commissioner (Appeals). 5. Heard both sides and perused the appeal records. 6. On perusal of the impugned order it has been observed that the Lower Appellate Authority has not proceeded on the basis of the consumption certificate issued by the Chartered Engineer only on the premise that the quantity of tonnage of steel mentioned in the Certificate cannot be equated with the monetary amount of confirmed amount of demand. The Ld. Commissioner (Appeals) has not disputed the usage of the steel items in the installation of Plant and Machinery. The Ld. Chartered Accountant during the course of hearing made the Bench go through the Chartered Accountant's Certificate certifying the CENV....