Rule 14 CCR, 2014: "Wrongly" Defined for Interest and Penalty on CENVAT; Focus on Incorrect Availment, Not Utilization.

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....Scope of the term "Wrongly" - Rule 14 of CCR, 2014 - Demand of Interest and penalty - availment of CENVAT and utilization thereof - it is unusual for ‘utilization’ to be qualified with ‘ineligibility’ on its own as ‘utilization’ is solely for the purpose of discharge of tax/duty liability which, even if not warranted, does not, by any stretch of usage, behove description as ‘wrongly.’ Such transfer of epithet, borne out of drafting frailty, can only reasonably mean ‘utilization’ after having been wrongly taken and, therefore, ineligible. - AT....