TaxTMI 
TaxTMI 
2024 (4) TMI 859
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....e manufacture of Ayurvedic Medicaments, namely. Sat Reetha, Herbal Sat, Neem Sat, Meghdoot Herbal Powder, Hring Raj Tail, and Triphla Brahmi Tail. On 16.04.1994, the Appellant declared the abovementioned products under Chapter sub-heading 3003.03 of the Central Excise Tariff Act 1985. 2.2 As the revenue was of the view that the products would be appropriately be classifiable under Chapter Heading 3305 instead of 3003. Accordingly, a show cause notice was issued and Commissioner, Central Excise, Lucknow adjudicated the case under Order-in-Original No. 9/99 dated 29.10.1999, holding the goods to be classifiable under heading 3305. 2.3 Tribunal vide Final Order No. 44-46/CE dated 28.01.2003 allowed the appeal filed by the appellant on limitation, leaving the issue of classification unsettled. An appeal was filed by the Appellant before the Hon'ble Supreme Court. Hon'ble Apex Court vide its Order dated 08.10.2004 in Civil Appeal No. 7445 of 2003 held that the products are classifiable under Chapter Heading 3003.30 2.4 During the pendency of this appeal before the Hon'ble Supreme Court, upon the insistence of the Department, the Appellant deposited an amount of Rs. 5,51,739/- u....
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.....01.2004 reference is drawn to the following table: S.No. Original Price Discount Percentage Discounted Price Amount of CED Price after 16% Central Excise Duty and 9.25% State Sales Tax 1. 56,600 40% 33,960 2. 56,600 52.1% 27,111.4 4,337.80 33957 or 33960 • As per Section 12(B) of the Act, it is the duty of the Appellant to prove that he has not passed the excise duty to the buyer. • They placed certain documents by way of supplementary affidavit and on the basis of the same it is submitted that the same was on record of the Revenue and from the same it is crystal clear that the Appellant has not passed on the excise duty to the buyers. • Thus they absorbed the duty, and the incidence of tax was not passed to the customers thereby making them eligible for refund. • Despite above the letters informing the dealers, the Appellate authority in para 12 gave a finding that the Appellant neither informed their buyers regarding duty absorption nor they have shown conclusively that the duty burden was effectively absorbed by them. • Even the fact that ....
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....duty has not been properly discharged by the Appellant and the duty was passed onto the buyers. Itis an established fact that the Appellant is eligible for a refund and not granting the same would be illegal and against the principles of natural justice 3.3 Arguing for the revenue learned authorized representative reiterates the findings recorded in the impugned order. 4.1 We have considered the impugned order along with the submissions made in appeal and during the course of arguments. 4.2 Hon'ble High Court has while remanding the matter back to tribunal for reconsideration has observed as follows: "It appears from the record that during the pendency of the appeal, the application for amendment (C.M. Application No. 60609 of 2019) was preferred and the same was allowed by this Court vide order dated 14.05.2019 and pursuant to the same, the amendment was incorporated by adding sixth substantial question of law. The questions of law mentioned in the memo of appeal, after amendment, read as under:- "1. Whether or not the bar of unjust enrichment will be attracted in a case where duty was paid under protest and specific letters were written to the dealers e....
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....ed on the excise duty to the buyer. For the purposes of decision on the question framed by us, we feel it appropriate to quote the relevant portion of the order of the Tribunal dated 10.12.2009, under appeal, which on reproduction reads as under:- "6. I have carefully considered the submissions from both sides and perused the records. There is no dispute that on merits, the appellants are eligible for the refund claimed by them. In fact, the refund has been sanctioned and credited to the Consumer Welfare Fund. The letters addressed to the dealers (according to the learned Consultant they are representative in nature) show that as if consequent to payment of duty the appellants were absorbing the burden of duty and the prices remained the same as it was prior to the period when the duty was not being paid. Provocation for issue of such letters is not furnished. There is no reference in the said letters of any resistance of the buyers to buy the goods with the element of duty. After all, the central excise duty is an indirect tax and the role of the manufacturer and the dealer down the chain of sale is to pass on the burden to the ultimate consumer. No evidence whatsoever ha....
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....dari Lal, AIR 1966 Pun 227). A judgment is the expression of the opinion of the Court arrived at after due consideration of the evidence and the arguments, it means a judicial determination, (vide: U.J.S. Chopra v. State of Bombay, AIR 1955 SC 633: 1955 SCJ 603: (1955) 2 SCR 94; and State of Bihar v. Ram Naresh Pandey, AIR 1957 SC 389: (1957) SCC 282: 1957 Cr LJ 567). Thus, in view of the above, the law can by summarised that the 'judgment' means a decision adjudicating upon the legal rights and liabilities of the parties after appreciating the evidence on record in a particular fact-situation, and that has to be duly supported by reasons. The Apex Court in the judgment passed in Civil Appeal Nos.3448- 3449 of 2019 (Kushuma Devi v. Sheopati Devi (D) & Ors.) observed as under:- "9. This Court has consistently laid down that every judicial or/and quasi-judicial order passed by the Court/Tribunal/Authority concerned, which decides the lis between the parties, must be supported with the reasons in support of its conclusion. The parties to the lis and so also the appellate/revisionary Court while examining the correctness of the order are entitled to k....
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....e placed reliance upon the Hon'ble CESTAT's order in the case of Tecil Chemicals and Hydropower Ltd. Vs CCE, Cochin, as reported in 2003(151) ELT 136. The appellants also relied upon the judgment of Hon'ble Supreme Court in the case of CCE, Kolkata Vs Panihati Rubber Ltd., as reported in 2006(76) RLT 551(SC). In this connection, I note with interest that Hon'ble Supreme Court in the Panihati Rubber Ltd. case, supra, have held that question whether incidence of duty has been passed on to buyers or not, is a question of fact and findings of fact arrived at by CESTAT is ordinarily to be accepted by the Supreme Court. Thus, the important issue here is as to whether the appellants have properly justified their claim on the fact that the burden of duty has not been passed on to the buyers. 11. I note that the Ld. adjudicating authority has observed in para 10 of the order that the set of invoices submitted with the refund claims are thoroughly scrutinized. The invoices issued between 11.09.2003 to 30.01.2004 clearly show the Central Excise duty @ 16% separately which is included in the price of the goods charged from the customers. This proves that the Central Excise duty has be....
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....uty had been passed on by him to any other person and the amount otherwise refundable shall be credited to the Consumer Welfare Fund. Sec 12 B specifies that- Every person who has paid the duty of excise on any goods under this Act shall, unless the contrary is proved by him, be deemed to have passed on the full incidence of such duty to the buyer of such goods 10. I find that the set of invoices submitted with the refund claims are thoroughly scrutinized. The invoices issued between 11.09.03 to 30.01.04 clearly show the Central Excise duty @16 % separately which is included in the price of the goods charged from the customers. This proves that Central Excise duty has been collected from the customers therefore, the incidence of duty has been passed on to others. 11. Though Central Excise duty is not shown in another set of invoices pertaining to the period from 01.07.03 to 10.09.03 and from 01.02.04 to 30.04.04, the chart enclosed indicates the Central Excise duty separately which is included in the net bill amount as shown in the invoices. Obviously, Central Excise duty shown separately were collected from the customers. 12. Party's co....
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....at they are charging the central excise duty from their customer, while maintaining the selling price at the same level by increasing the discount given from 40% to 52.10%. Undisputedly appellant himself admits that they are charging the central excise duty from their customers. That being so the burden of duty paid has been passed on the customer. The reason for giving additional discount to the customers can be many including the product competitiveness. However we are not concern with the appellant offering additional discounts to their customers, we restrict ourselves to the fact that appellant state in these letters that they are charging the duty from their customers. 4.9 Appellant had also written letter dated 05.08.2003 to the jurisdictional Assistant Commissioner as follows: From the above letter also it is evident that the said letter is totally silent in respect of passing the burden of duty on to the buyers. Further this letter is only in respect of payment of certain duties under protest for the period April to July 2003. We are not concerned with that period in the present proceedings. Hence we do not find any merits in the submissions made by the appellant on t....
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.... of clearance of the goods, prominently indicate in all the documents relating to assessment, sales invoice, and other like document, the amount of such duty which will form part of the price at which such goods are to be sold. SECTION 12B Every person who has paid the duty of excise on any goods under this Act shall, unless the contrary is proved by him, be deemed to have passed on the full incidence of such duty to the buyer of such goods. Interpreting the provisions of above two sections Hon'ble Supreme Court has in case of Mafatlal Industries [1997 (89) ELT 247 (SC)] observed as follows: "91. It is next contended that in a competitive atmosphere or for other commercial reasons, it may happen that the manufacturer is obliged to sell his goods at less than its proper price. The suggestion is that the manufacturer may have to forego not only his profit but also part of excise duty and that in such a case levy and collection of full excise duty would cease to be a duty of excise; it will become a tax on income or on business. We are unable to appreciate this argument. Ordinarily, no manufacturer will sell his products at less than the cost-price plus duty. H....
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....the levy of duty is upon the manufacturer/assessee and that he cannot disclaim his liability on the ground that he has not passed on the duty. This is undoubtedly true but this again does not affect the validity of Section 12A or 12B. A manufacturer who has not passed on the duty can always prove that fact and if it is found that duty was not leviable on the transaction, he will get back the duty paid. Ordinarily speaking, no manufacturer would take the risk of not passing on the burden of duty. It would not be an exaggeration to say that whenever a manufacturer entertains a doubt, he would pass on the duty rather than not passing it on. It must be remembered that manufacturer as a class are knowledgeable persons and more often than not have the benefit of legal advice. And until about 1992, at any rate, Indian market was by and large a sellers' market." 4.13 From the table in para 4.11, it is quite evident that appellant had on the invoices 131, 137, 157,227 and 276 paid the duty @ 16% on assessable value of Rs 38.80. Thus making the cum duty price of Rs 45.01. On the invoices 78,82,95 & 99 they have paid Nil duty on assessable value of Rs 48.60, so the cum duty price would be ....
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....ghtly held by the Commissioner (Appeals) this is only a presumption and the appellants were required to produce evidence that they have not actually passed on the duty burden, which they have failed to do either before the adjudicating authority as well as the lower appellate authority. As there is no material on record produced by the appellant to establish that they have not passed on the duty burden to their customers, the refund claim has been rightly rejected. We therefore uphold the impugned order and dismiss the appeal." 4.16 In case of Sona Udyog [2005 (183) E.L.T. 396 (Tri. - Del.)] Delhi bench has observed as follows: "5. In pursuance to the above order passed by the Hon'ble Supreme Court, the applicant filed these applications. The contention of the appellant is that the issue of unjust enrichment was specifically raised before the Tribunal and the finding that of such plea was raised, is a correct finding. The contention of the appellant is that specific issue was raised regarding unjust enrichment by saying that when no change has been taken place in the price structure, it cannot be said that the incidence of duty has been passed on to their customers. The....
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....should not interfere under Article 136 of the Constitution in view of the concurrent finding of fact". 7. In the present case the contentions are that the above decision of the Hon'ble Supreme Court is not applicable to the facts of the case on the ground that the Supreme Court was dealing a case where the invoices in question are not of manufacturers. We find that as the Supreme Court was dealing the issue regarding unjust enrichment and the law laid down by the Supreme Court is in respect of the specific plea that in case price remains same, the burden of payment of duty has not been passed on to the buyer and this issue is decided in favour of the Revenue by the Supreme Court, therefore, we find no merit in this argument of the applicant. As the issue raised by the appellant in specific answer by the Supreme Court, therefore, we find no merit in these applications, the same are dismissed." 4.17 In case of Interach Building Products (P) Ltd [2005 (184) E.L.T. 154 (Tri. - Del.)] Delhi bench held as follows: (Maintained by Hon'ble Supreme Court as reported at [2006 (193) E.L.T. A143 (S.C.)] "7. This very principle of law has been followed and applied by the Tri....
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.... as to what was the price agreed upon and how much was the duty element therein. When the duty element, as observed above, had been separately shown, besides the price, in the invoices, by the appellants, that itself is enough to make his affidavit meaningless." 4.18 Appellant have heavily relied upon the decision of Hon'ble Calcutta High Court reported at [2004 (172) ELT 310 (Cal)] to argue that in the present case principles of unjust enrichment would not apply. However Hon'ble Supreme Court as reported at [2006 (202) E.L.T. 41 (S.C.)] in the appeal filed against this order, held as follows: "8. It is now well settled that despite levy of excise duty in a given situation being held to be illegal, in the event it is found that the assessee in fact passed on the burden of excise duty to its customers, applying the principle of unjust enrichment, the Court would not ordinarily direct refund thereof. 9. The question whether the excise duty had been passed on to the consumer, however, is essentially a question of fact. It is not in dispute that prior to 1993 goods were being classified under the Sub-Heading 4009.92 of the Schedule appended to the Central Excise Ta....
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....¤œ डà¥à¤¯à¥‚टी नहीं लगेगी। इसलिठहम à¤à¤•à¥à¤¸à¤¾à¤‡à¤œ विà¤à¤¾à¤— के कहने के अनà¥à¤¸à¤¾à¤° आपको उपरोकà¥à¤¤ टैरिफ के उतà¥à¤ªà¤¾à¤¦à¥‹à¤‚ पर 16% डà¥à¤¯à¥‚टी चारà¥à¤œ करेंगे परनà¥à¤¤à¥ हम आपको पूरà¥à¤µ में दिठजा रहे 40% छूट की जगह 52.10% छूट देंगे जिससे आपसे जितना हम à¤à¤•à¥à¤¸à¤¾à¤‡à¤œ चारà¥à¤œ करेंगे उतना à¤....
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....स सनà¥à¤¦à¤°à¥à¤ में à¤à¤• अपील सरà¥à¤µà¥‹à¤šà¥à¤š नà¥à¤¯à¤¾à¤¯à¤¾à¤²à¤¯ में सà¥à¤µà¥€à¤•à¥ƒà¤¤ हो चà¥à¤•à¥€ है, परनà¥à¤¤à¥ सà¥à¤¥à¤¾à¤—न आदेश नहीं मिला है à¤à¤¸à¥€ सà¥à¤¥à¤¿à¤¤à¤¿ में मेरा निवेदन है कि हमारी फरà¥à¤® मेघदूत गà¥à¤°à¤¾à¤®à¥‹à¤¦à¥à¤¯à¥‹à¤— सेवा संसथान में 2 पà¥à¤°à¤•à¤¾à¤° के उतà¥à¤ªà¤¾à¤¦ बनाये जाते है, पहले वरà¥à¤— के उतà¥à¤ªà¤¾à¤....
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....¾à¤¦ शà¥à¤²à¥à¤• विà¤à¤¾à¤— दà¥à¤µà¤¾à¤°à¤¾, बजट 2003-04 दà¥à¤µà¤¾à¤°à¤¾ परिवरà¥à¤¤à¤¨ आधार पर उतà¥à¤ªà¤¾à¤¦ शà¥à¤²à¥à¤• देने हेतॠकोई निरà¥à¤¦à¥‡à¤¶ हमें पà¥à¤°à¤¾à¤ªà¥à¤¤ नहीं हà¥à¤† है। पà¥à¤°à¤¥à¤® बार विà¤à¤¾à¤—ीय अधिकारियों दà¥à¤µà¤¾à¤°à¤¾ आज हमे बताया गया, की चाहे उतà¥à¤ªà¤¾à¤¦ शà¥à¤²à¥à¤• मà¥à¤•à¥à¤¤ हो, या शà¥à¤²à¥à¤• देय हो, के विकà¥à¤°à¤¯ मूलà¥à¤....
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.... के आदेशानà¥à¤¸à¤¾à¤° कारà¥à¤¯ करेंगे। उपरोकà¥à¤¤ अनà¥à¤¸à¤¾à¤° हम समसà¥à¤¤ कर की गणना करके निरà¥à¤§à¤¾à¤°à¤¿à¤¤ कर शीघà¥à¤° अंडर पà¥à¤°à¥‹à¤Ÿà¥‡à¤¸à¥à¤Ÿ जमा कर रहे हैं। उपरोकà¥à¤¤ हेतॠहमे उचित निरà¥à¤¦à¥‡à¤¶ देवें । à¤à¤µà¤¦à¥€à¤¯ पà¥à¤°à¤¬à¤¨à¥à¤§à¤•" Document 5 078 Serial No MS Meghdoot Gramodyog Sewa Sansthan Fact: Nabl Kot Nandana, Sitapur Road, Lucknow H.O333, Chandralok Colony, Lucknow. 1 Full Postal Address of Range Chowk, 7-A, Ashok Marg, Lucknow. Il Full Postal Address of Division:....
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....abl Kot Nandanc, Sitapur Road, Lucknow H.O.: 303, Chandralok Colony, Lucknow. L. Full Postal Address of Range Chowk, 7-A, Ashok Marg, Lucknow. IL Full Postal Address of Divislar Chowl, 7-A, Ashok Marg, Lucknow. (Central Excise Reg. No. 21/CK/ Lko/58. ECC No.: AAAAM1666KXM001) M Name and Address of Consignee MS मेहर मिले য10 লিठ—འི་ང་༢-༧་་འ-༥༦6-༥ལོན་ཤ XV Date & Time of issue of invoice 19.77003 In words PRE-AUTHENTICATION ised Signatory Discription 4 Specification of goods 3 IV 77 ह‌नà¥à¤®à¤¾ No, and Description Tou Toualice Quarility 2 of 9 10004 Packagers goods (ne) V VI V 3xa Duty Прим IN x XI хи XIII W STRA 120 23025-2000 16×40 4C0 200 3 124 12 40 23-0035:10:00 2002:39 NIL MIL 10stos 40%, 48420000300235 1860 11040-705002-85 18:40:5:00 Infoins 3002.35 MIL 43016 Serial no. of debit entry ....
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....ar given above are true and corruct and the amount indicated represents the price actually charged and that there is no flow additional considuration directly or indirectly from the buyer. Note: Value indicated against S. No ix) and (x) shall correspond to the assessable value determined in invoice or as indicated in the deglaration filed or tariff value as the case may be. The rate of duty and the amount of duty given against S. No. (xii) and (xii) should be indicated sepe-ately for each type of dut ns, such as baric duy, additional duty, coss cc. UPT.T. No LK 0200031-10-09-06 C.S.T. No: L-S Signature Licenseo orthorised agent Document 8 Serial No 4 Meghdoot Graxiod yng Sewa Sansthan 099 Feet: Nabi Kot Nan dane, Sitapur Read, Lucknow CHO.: 303, Chandralok Colony, Lucknow. & Full Postal Address of Range : Chowk. 3-A, Ashok Marg, Lucknow. Full Postal Address of Diviston: Chow, 7-A, Ashok Marg, Lucknow. (Central Excise Reg. No. 21/CLke/90 . ECC No.: AAA 31666M001) Name and Address of Consignee जोबन पिलेट 10 लिठ9 वी० à¤à¤....
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.... Time of issue of invoice In words 미1703 3:30PM. PRE-AUTHENTICATION M forised Signstory 1H5 Te Spe X XI Xi XI 20x 50 1000 39000 70 40 23-4523400:00 300335 MINIL 50x50 2500 5000:00 40% 15-2035000:00 3503-39 M ' (XIV) (XVI) (XVII) (XVII) TOTAL: HOCTB Serial no. of debit entry in FLAVRC 23. 94000:00 N.W. Date and time of removal c goods 11.07.003 $350 0670. Mode of uansport and motor vehicle registration. Centified that the particulars given above are true and correct and the amount indicated represents the price actually charged and that there is no flow additional conslueration directly or indirectly from the buyer. Note: Value indicated against S. No. (ix) and (x) shall correspond to the assessable value determined in invoigo or as indicated in t declaration filed or tariff value as the case may be. The rate of duty and the amount of duty given against S. No. should Le indicated seperately for each type of duties, such as basic cuty, additional dutyCess etc. and UP.T.T. LKC0831 wet. 08-09-05 CST No LK 5157321 wet 04.00 87 UP.CT. No. 16- 3,7, to LK- 4-3-07 Sig....
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....r the License or His Luthorised ager Document 11 Serial No A Meghdoot Craniorivog Sewa Sansthan 137 Fact: Nabl Ket Mandana, Sitapur Road, Lucknow H.O.303, Chandralok Colony, Lucknow. CL Full Postal Address of Range : Chowk, 7-A, Ashuk Marg, Lucknow. Fu Postal Address of Division: Chows, 7-A, Ashok Marg, Lucknow. (Central Excise Reg. No. 21/CK/LL0 /04 ECC No: AAAM163CKXM001) Name and Pudress of Consignee 6 ,。。,1ã€..120) 20 XV Date & Time of issue of invol e in words 18.9.003 10:15MG PRE-AUTHENTICATION horised Signatory Discription A Specification of goods No and Description of Total Quantity of Total Price goods Packaners goods (net) Vi IV V मधà¥à¤£à¥‡ ३० ды g V IX X XI 201 16x20 200 2008-00:00 3003-3416 Tox:40 400 18400/23038012:70 361-35 161 20×50 1000 22000:00201051040000023516) 200 Evic 2 Duty 433742 44442 2015 334 S T Dutya Spe XIII 4 40-e1B Schoorts Serial no. of debit entry in PLARG 23.163.003 Date and tine of removal of g....
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....001051038-760:00 00:39 161. 3360000 5270113041 1604.20 3103.38 16/. दल*5 10 221) 26.34 3292 10 103.38 K) 139227.10 Eveisajuly with 34 - - - to CIB. TOTAL: (XIV) Serial no. of cebit entry in PLARG 23 15.10.003. (XVI) Date and time of removal of goods (XVII) Biode of transport and motor vehicle registration. (XVIII) 44113-11 19143.71 - PM.... Certified that the particulars given above are true and correci ard the amount indicated represents the price ectuy charged and that there is no flow additional consideration directly or indirectly from the buyer. Note:Value indicated against S. No. (x) and (x) shall rorrespond to the assessable value determined in invoice odidetod in the declaration flied or tariff value as the case may be. The rate of duty and the amount of duty given against No. (xii) and (xi) should be indicated superately for each type of duties, such as hasic cuty, additional duty, cess ctc. UPT.T.No LK-020831 wef 08-09-86 CST. No: LK-515/321 wel. 04-08-87 UP.ST. C.S.T. I Coa ཞའལ་ ་ धरà¥à¤®à¤°à¤¾à¤œ Signatur....
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....C.S. T. No.: LK-5157321 wel. 04-08-87 U.P.S.T. tio. LK-0245311. 6-9-80 C.S.T. No. LK-5121 ww, 4-4-37 Siopalute of the License of his authorised agen Document 14 A Serial No INVOICE UNDER RULE 52-A, 173-C For Offic Meghdoot Gramodyog Sewa Sansthan 276 Fact: Nabi Kot Nandana, Sitapur Road, Lucknow H.O.: 303, Chandralok Culony, Lucknow. L. Full Postal Address of Range Chowk, 2-A, Ashok Marg, Lucknow. 1. Full Postal Address of Division: Chowk, 7- A, Ashok Marg, Lucknow. (Central Excise Rag. No. 21/CK/Lko.98. ECC No.: AALAM1666KXM001 ) Name and Address of Consignee Ms a बोवून कà¥à¤²à¤¿à¤‚ग पà¥à¤°à¥‹à¤¡à¤•à¤° মসত 14 AV Date & Time of issue of invoice in words 24.0184 10:30then FRE-AUTHENTICATION Authorised Signatory FAT Ðто раморно 6500 Discription & Specification of goods No. and Description Titl Quanuty Total Price of of of goods Packagers goods (net) V Vi Vil VIII EX x 2+5 Tw Duty 8p XI XII....