2026 (5) TMI 876

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....gs by the Adjudicating Authority when the matter was placed before him as per the directions of the Hon'ble High Court. Since the issue is common and arises out of the common OIO, we have taken up all the present appeals together for disposal. 2. The Ld AR representing the appellant Revenue, reiterates the grounds taken by them in their Appeal paper book. He submits that the Adjudicating authority erred in dropping the demand and prays that the present Appeals may be allowed. 3. On going through the detailed Order in Original passed by the Adjudicating Authority we find that he has held that the Revenue could not produce the person for cross-examination as was directed by the Hon'ble High Court. The Adjudicating Authority at Para 79 o....

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....e territory of India". i.e. ratio of above mentioned judgements/findings need to be applied equally to all notices/conoticees, who are similarly placed vis-à-vis statements of key witnesses Shri Narendra Lodaya and Shri Dhaval Lapasiya." 4. We also find from the present appeal filed by the Revenue that it is an admitted fact in the Grounds of Appeal that the Certificates of Origin issued by the Overseas country still stand as a valid document and has not been cancelled as on date. The entire case of the Revenue hinges on their allegation that the Certificates of Origin are not proper, which gets negated by the fact that even as on the date of this Hearing, these Certificates of Origin have not been cancelled by the issuing country....