2025 (3) TMI 496

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....EMBER (TECHNICAL) Shri Deepro Sen & Mr.Shovit Betal, both Advocates for the Appellant Shri S.Dey, Authorized Representative for the Respondent ORDER Per Ashok Jindal : The appellants are in appeals against the impugned order contesting the issue of limitation only. 2. The facts of the case are that the appellant is engaged in the manufacture of Zinc Calots, Rechargeable Batteries, Zinc Ash (Scrap), Alkaline Battery falling under CTH 7905 0010, 8507 8000, 2620 1900 and 8506 8090 of the1st Schedule to the Central Excise Tariff Act, 1985. 2.1 The Appellant during the relevant period of June 2010 to December 2013 imported bare rechargeable cells in bulk. It undertook activity of testing and labelling such cells at its facto....

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.... the excise duty was payable on the value at which such goods were ultimately sold by Appellant from its depot (as per price list). 2.8 The entire amount of demand proposed vide the SCN was confirmed by the Ld. Principal Commissioner vide O-I-O dated 14.03.2016 along with interest and penalty. Personal penalties were also imposed on three employees of the Company. 2.9 Being aggrieved with the said order, the appellants are before us. 3. The ld.Counsel for the appellants, without going into the merits of the case, submitted that an audit was conducted in their premises and spot memo dated 25.07.2012 was issued , which was replied by the appellants on 27.09.2012. But the show-cause notice has been issued to the appellants on 07.07.20....