2025 (6) TMI 2145

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....N, MEMBER (TECHNICAL) For the Appellant : Shri N. K. Chowdhury, Advocate For the Respondent : Shri S. K. Jha, Authorized Representative PER R. MURALIDHAR The appellants are manufacturer of Transformer components which are supplied to two of their sister units namely M/s. RTS Power Corporation and M/s. Rajasthan Transformers and Switchgears. These components are used by the sister conce....

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....e sister concerns as Cenvat Credit. In such a case, though they might not have added 10% profit margin in terms of Rule 8, still there is no Revenue loss and the entire transaction is revenue neutral. 3. He relies on the case law of Anglo French Textiles Vs. Commissioner of Central Excise, Puducherry [2018 (360) E.L.T. 1016 (Tri.-Chennai)] wherein it is held that since the Cenvat Credit would a....

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....t the assessable value. Apart from this, it is clear from the records that they have not added 10% profit margin which is required to be added as per Rule 8 of Valuation Rules, 2000. Therefore, he prays that the appeal may be dismissed. 6. Heard both sides and perused the appeal papers and the cited case law. 7. We find that there is no dispute that the components despatched by the appellant....

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....ase, even if the appellant is directed to pay duty, other sister unit would be eligible for the credit. In the case of Jay Yuhshin Ltd. (supra), in a similar situation, the Larger Bench of the Tribunal has held that when there is revenue neutrality, the demand of duty is unsustainable. 6. We find that it is a fit case to set aside the demand on the basis of revenue neutrality which we her....