Show Cause Notice Invalid: Incorrect "Related Person" Assumption and Misapplication of Rule 8 Against Appellant's Coal Washery.

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....Valuation - Scope of the SCN - Since the entire foundation of the show cause notice is based on the wrong notion that the washery is a “related person” of the appellant, the entire demand is liable to be quashed. Further the invocation of Rule 8 of the Valuation Rules has been done mechanically without even appreciating the fact that there is no captive consumption by the appellant or consumption on its behalf and washing of coal is neither production nor manufacture. - AT....