TaxTMI 
TaxTMI 
2026 (9) TMI 1208
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....ted 13.05.2022 passed by the Commissioner of CGST (Appeals), Dehradun in which he remanded the matter to the original authority for denovo adjudication for the limited purpose of verifying the appellant's contention that they had removed goods, as such, after reversal of proportionate credit after affording opportunity of being heard to the appellant. On merits, the Commissioner (Appeals) upheld the findings of the original authority in his order dated 13.10.2021. 2. The facts of the case, in brief, are that the appellant manufactures automobile parts and accessories and sells them to original equipment manufacturers (OEMs) who are manufacturers of automobiles. In order to manufacture the parts, the appellant requires tools and dies. In ....
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....ds. 5. There is no dispute that the final products cannot manufactured without the tools, moulds or dies and, therefore, they should form part of the assessable value. Since they are used for a period of time only, the amortized value of these should be included in the assessable value of the final products. In cases where tools and dies were supplied by the customers free of cost, the appellant had included the amortized value of such tools and dies in the value of the final products. There is no dispute to that extent. 6. However, where the appellant had itself manufactured or procured the tools and dies and recovered the cost from the customers through separate invoices issued to them, the appellant had not included either their to....
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....over all the goods manufactured using it. This is done through an accounting method known as amortization in which the total value of the tool or die is divided over the number of final goods which are likely to be products using it and proportionate value of the tools and dies is added to each good. The appellant had done so where the tools and dies were supplied by the customers. However, the appellant did not do so when it produced the tools and dies and sold them to the customers through separate invoices. We have no reason to believe the appellant was not aware that the amortized value of tools and dies was to be added to the final products when it had done so in those cases where the tools and dies were supplied by the customers. 1....