2021 (11) TMI 14
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....hat during the course of audit for the period April 2011 to March 2013 by Departmental officers, it was observed, that the appellant are engaged in manufacture of dutiable Spray Nozzles and trading of goods such as pipes and compressors; that the appellant was availing CENVAT credit on certain input services which were commonly used in manufacturing and trading activity; that no separate accounts were maintained for the same; that immediately upon intimation by the Departmental Officers, the appellant reversed credit amounting to Rs. 18,93,884/- as the credit attributable to the common input services used for trading/exempted supplies as well as taxable supplies, for the period of July 2010 to March 2015, such reversal was done without appl....
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....emand of Rs. 5,94,034/- for the disputed period along with applicable interest and penalty, against which, the present appeal is filed. The reasons given by the authority below are that the appellant had previously reversed the demanded amount for the period under dispute and that the appellant had made the payments after exercising option under Rule 6(3A) after the due date had elapsed. 5. Heard rival contentions and have carefully gone through the decisions/orders relied upon during the course of arguments, I find that in one of the recent orders, learned Ahmedabad Bench of CESTAT in the case of CCE Vs Reliance Industries Ltd, 2019 (28) GSTL 96 (Tri. Ahmd.) while analysing an almost identical issue, has held as under: "8. From the read....