2000 (11) TMI 214

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.... of the appellants before us, M/s. Vadilal Embroidery Unit (Vadilal for short) and M/s. Doshi Industrial Corporation (Doshi for short) were engaged in embroidery of grey fabrics. Each of them paid duty on the embroidered fabrics according to law and, thereafter, handed over the fabrics to M/s. Dura Processors for processing. Notice was issued to both these firms, and to M/s. Dura Processors to pay....

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....r processing the same fabrics. The appeal by Dura Processors against that order is separately being dealt with. 3. Two distinct and separate questions had to be answered by the Commissioner (Appeals). The one raised by the Vadilal and Doshi was that they did not process the fabric that they embroidered, and hence were not required to pay the duty on that processing. The second, raised by Dura Pro....

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.... of duty for that processing. If any duty is payable on such processing, (on which we do not at present express any opinion, it is payable by the person who carried out that processing. 5. The departmental representative relying, he says, on instructions from the Commissioner, contends that the present appellants are liable to pay the duty, citing the provisions of Notification 27/92. This notifi....