2006 (2) TMI 195

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....ght to raise the following two questions of law - 1. "Whether in the facts and circumstances of the case and in law the Hon'ble CESTAT erred in holding that : (i) despite the admitted non-compliance of the prescribed procedure Rule 57F (4) by the Respondents herein, the burden to prove that such non-compliance could result in any wrongful gain to the Assessee who claimed Modvat credit, would shif....