w w w . L a w y e r S e r v i c e s . i n



Commissioner, CGST & Central Excise, Jaipur V/S Genus Power Infrastructure Ltd.


Company & Directors' Information:- G K S INFRASTRUCTURE LIMITED [Active] CIN = L45400DL1985PLC021038

Company & Directors' Information:- A INFRASTRUCTURE LIMITED [Active] CIN = L25191RJ1980PLC002077

Company & Directors' Information:- K D P INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U74899DL1993PTC054780

Company & Directors' Information:- K P INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45203GJ2004PTC043482

Company & Directors' Information:- C INFRASTRUCTURE CORPORATION LIMITED [Strike Off] CIN = U61100DL1982PLC013968

Company & Directors' Information:- B & G INFRASTRUCTURE COMPANY PRIVATE LIMITED [Active] CIN = U40105TN2001PTC047408

Company & Directors' Information:- O B INFRASTRUCTURE LIMITED [Active] CIN = U45200TG2006PLC049067

Company & Directors' Information:- K U INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45206TG2008PTC096209

Company & Directors' Information:- Y T INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45202MH2010PTC206409

Company & Directors' Information:- N K B INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200HR2011PTC042402

Company & Directors' Information:- R K D INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45209WB2009PTC131919

Company & Directors' Information:- B AND B INFRASTRUCTURE LIMITED [Active] CIN = U85110KA1987PLC008488

Company & Directors' Information:- K A J INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U70101DL2011PTC217204

Company & Directors' Information:- G M P INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45400TG2009PTC066367

Company & Directors' Information:- U C C INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201MH2003PTC139844

Company & Directors' Information:- R L INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U70102UP2010PTC041755

Company & Directors' Information:- L K INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45400MH2010PTC203711

Company & Directors' Information:- B S R INFRASTRUCTURE PRIVATE LIMITED [Converted to LLP and Dissolved] CIN = U70101KA2006PTC038204

Company & Directors' Information:- B N A INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201MH2006PTC163769

Company & Directors' Information:- S K J INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45102MH2001PTC131284

Company & Directors' Information:- K B A INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45202MH2009PTC194291

Company & Directors' Information:- V P M INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45400TN2011PTC082368

Company & Directors' Information:- K INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201GJ2009PTC056299

Company & Directors' Information:- D G INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45401MH2004PTC146369

Company & Directors' Information:- E K INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200TN2008PTC066962

Company & Directors' Information:- A & A INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U74899DL1976PTC008196

Company & Directors' Information:- K L N INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U70100KA2013PTC070361

Company & Directors' Information:- C P INFRASTRUCTURE PVT LTD [Active] CIN = U45201DL2005PTC143865

Company & Directors' Information:- G. R. INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200MH2005PTC152633

Company & Directors' Information:- R P INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200MH2003PTC141340

Company & Directors' Information:- K. J. INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201MH2006PTC165014

Company & Directors' Information:- CENTRAL INDIA POWER COMPANY LIMITED [Active] CIN = U40100MH1994PLC084055

Company & Directors' Information:- B S Y INFRASTRUCTURE PRIVATE LIMITED. [Active] CIN = U70101HR2006PTC064456

Company & Directors' Information:- M AND S INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45400TN2011PTC083038

Company & Directors' Information:- V K D S INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45400WB2013PTC197196

Company & Directors' Information:- G B K INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45202MH2008PTC177202

Company & Directors' Information:- G K INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45200GJ2005PTC046213

Company & Directors' Information:- G S M INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201DL2004PTC125377

Company & Directors' Information:- V K M INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45400UP2008PTC034606

Company & Directors' Information:- A V INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45203WB2006PTC111599

Company & Directors' Information:- S. J. INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200DL2006PTC155904

Company & Directors' Information:- B. N. S. INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45400MH2010PTC206202

Company & Directors' Information:- B G M INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45400WB2011PTC162415

Company & Directors' Information:- S M V INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200DL2006PTC155016

Company & Directors' Information:- K S INFRASTRUCTURE PRIVATE LIMITED. [Active] CIN = U70101MP2006PTC020722

Company & Directors' Information:- K B S INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U70101DL2005PTC136641

Company & Directors' Information:- D L H INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U52600JH2010PTC014524

Company & Directors' Information:- S N N INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45202KA2011PTC059893

Company & Directors' Information:- G. V. INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45400DL2012PTC234078

Company & Directors' Information:- S A P INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201DL2005PTC141285

Company & Directors' Information:- K S K INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45400DL2008PTC175908

Company & Directors' Information:- N P L INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45400CH2009PTC031638

Company & Directors' Information:- K. E. INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45400MH2012PTC225658

Company & Directors' Information:- P A S INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200DL2006PTC155015

Company & Directors' Information:- G S T INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200MH2006PTC160073

Company & Directors' Information:- D. N. POWER INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U31900HR2009PTC039239

Company & Directors' Information:- P J INFRASTRUCTURE PVT LTD [Active] CIN = U45200MH2006PTC159217

Company & Directors' Information:- S B M INFRASTRUCTURE LIMITED [Active] CIN = U70102CH1992PLC012381

Company & Directors' Information:- A V C INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U70102TG2007PTC056671

Company & Directors' Information:- V D INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45400WB2008PTC122820

Company & Directors' Information:- I V M INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45209TG2011PTC073968

Company & Directors' Information:- U S INFRASTRUCTURE INDIA PRIVATE LIMITED [Strike Off] CIN = U74999DL2002PTC117525

Company & Directors' Information:- B G R INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45202KA2012PTC065026

Company & Directors' Information:- N. R. INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45202GJ2006PTC049520

Company & Directors' Information:- K. G. R INFRASTRUCTURE PRIVATE LIMITED. [Strike Off] CIN = U70102DL2008PTC177822

Company & Directors' Information:- A L INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200MH2008PTC184347

Company & Directors' Information:- CENTRAL INDIA INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200MH1999PTC120157

Company & Directors' Information:- N B INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201OR2008PTC009989

Company & Directors' Information:- C. I. INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45203MP2005PTC018149

Company & Directors' Information:- S G INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201RJ1999PTC015467

Company & Directors' Information:- J N INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201OR2008PTC009789

Company & Directors' Information:- K C INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200PB2008PTC032011

Company & Directors' Information:- C C I INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201TN2007PTC063617

Company & Directors' Information:- A Q INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45400MH2010PTC203965

Company & Directors' Information:- A B INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200MH2004PTC144994

Company & Directors' Information:- S H A INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45400UP2012PTC049795

Company & Directors' Information:- L V S INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200TG2006PTC051289

Company & Directors' Information:- V H B INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45400DL2008PTC172682

Company & Directors' Information:- G A V INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U74999DL2007PTC158113

Company & Directors' Information:- S & I INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45400HR2007PTC037191

Company & Directors' Information:- V V S INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U70100KA2015PTC084214

Company & Directors' Information:- D L INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201CT2018PTC008919

Company & Directors' Information:- G. H. INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45309UP2020PTC126090

Company & Directors' Information:- L R INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45402TN2007PTC064029

Company & Directors' Information:- G. D. INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45209MH2010PTC208011

Company & Directors' Information:- G N R INFRASTRUCTURE (INDIA) LIMITED [Strike Off] CIN = U45200TG2009PLC065140

Company & Directors' Information:- A R K INFRASTRUCTURE INDIA PRIVATE LIMITED [Strike Off] CIN = U74900TG2015PTC100714

Company & Directors' Information:- U V F INFRASTRUCTURE LIMITED [Active] CIN = U45400WB2010PLC153786

Company & Directors' Information:- B K INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45201DL2005PTC136992

Company & Directors' Information:- R A INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U74899DL2005PTC143884

Company & Directors' Information:- C. A. D. INFRASTRUCTURE INDIA PRIVATE LIMITED [Strike Off] CIN = U45201MP1997PTC012280

Company & Directors' Information:- B R G INFRASTRUCTURE LIMITED [Active] CIN = U45201GJ2008PLC052708

Company & Directors' Information:- H. H. INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201GJ2008PTC054481

Company & Directors' Information:- O P L INFRASTRUCTURE PRIVATE LIMITED [Converted to LLP and Dissolved] CIN = U70101HR2009PTC039553

Company & Directors' Information:- C M INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201DL2003PTC122794

Company & Directors' Information:- L & C INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200KA2008PTC046271

Company & Directors' Information:- R. S. V. INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U70100WB2008PTC127373

Company & Directors' Information:- C D E INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201MH2012PTC235483

Company & Directors' Information:- V & B INFRASTRUCTURE (I) PRIVATE LIMITED [Under Process of Striking Off] CIN = U45400MH2010PTC206803

Company & Directors' Information:- D B G INFRASTRUCTURE (INDIA) PRIVATE LIMITED [Strike Off] CIN = U45209PN2010PTC137319

Company & Directors' Information:- C & C INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U74210PN2008PTC133179

Company & Directors' Information:- M N V INFRASTRUCTURE (INDIA) PRIVATE LIMITED [Strike Off] CIN = U45202AN2010PTC000130

Company & Directors' Information:- S C N INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U67200TG1995PTC021606

Company & Directors' Information:- R P V S INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45203TG2011PTC072772

Company & Directors' Information:- S P H R INFRASTRUCTURE PVT LTD [Strike Off] CIN = U45209WB2006PTC109280

Company & Directors' Information:- J V INFRASTRUCTURE PRIVATE LIMITED [Under Process of Striking Off] CIN = U45201DL2005PTC139686

Company & Directors' Information:- S I S INFRASTRUCTURE PRIVATE LIMITED [Under Process of Striking Off] CIN = U70200DL2014PTC263278

Company & Directors' Information:- A S INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U70109DL1996PTC084029

Company & Directors' Information:- P G INFRASTRUCTURE PRIVATE LIMITED [Converted to LLP] CIN = U70109DL1996PTC084030

Company & Directors' Information:- B S INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U70109DL1996PTC084031

Company & Directors' Information:- M S INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U70109DL1996PTC084032

Company & Directors' Information:- Z M INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200GJ2010PTC063179

Company & Directors' Information:- J B C INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45203PN1998PTC112753

Company & Directors' Information:- J K L INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45203TG1998PTC030087

Company & Directors' Information:- R L E S INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45309TN2008PTC069251

Company & Directors' Information:- I I C INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U70109DL2006PTC152588

Company & Directors' Information:- H. G. INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45201GJ2007PTC049740

Company & Directors' Information:- AND INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U74999PY2016PTC008099

Company & Directors' Information:- J INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U70200UR2012PTC000254

Company & Directors' Information:- T S INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U70100MP2008PTC021187

Company & Directors' Information:- G T INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45200GJ2011PTC064637

Company & Directors' Information:- G L INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201GJ2007PTC050660

Company & Directors' Information:- M I J INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45201DL2004PTC125213

Company & Directors' Information:- B T INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45202GJ2004PTC043463

Company & Directors' Information:- S B H INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U60231MH2011PTC217039

Company & Directors' Information:- Z & B INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U70200MH2007PTC166887

Company & Directors' Information:- S & O INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45400MH2011PTC214034

Company & Directors' Information:- D P S INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45200MH2006PTC159955

Company & Directors' Information:- M N A INFRASTRUCTURE PRIVATE LIMITED [Converted to LLP] CIN = U45400TG2009PTC063947

Company & Directors' Information:- T S A INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45400UP2014PTC065137

Company & Directors' Information:- V B G INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U70100TG2010PTC069278

Company & Directors' Information:- G S V INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45209TG2008PTC059195

Company & Directors' Information:- M N C INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45209TG2011PTC077524

Company & Directors' Information:- G K POWER & INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45400JK2013PTC003793

Company & Directors' Information:- M W INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201CH2008PTC031045

Company & Directors' Information:- M I T INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45400DL2008PTC180830

Company & Directors' Information:- V N INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45400DL2010PTC203928

Company & Directors' Information:- G J INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45400DL2012PTC239594

Company & Directors' Information:- A TO Z INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45400DL2014PTC272671

Company & Directors' Information:- K K S INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U74999DL2007PTC159678

Company & Directors' Information:- U R INFRASTRUCTURE COMPANY PRIVATE LIMITED [Active] CIN = U45201DL2004PTC127085

Company & Directors' Information:- I K INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201DL2005PTC135711

Company & Directors' Information:- S S T INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45201DL2005PTC137437

Company & Directors' Information:- D S INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201DL2005PTC138026

Company & Directors' Information:- A J S INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45201DL2005PTC140640

Company & Directors' Information:- M R INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45201DL2005PTC143565

Company & Directors' Information:- V INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U70200DL2009PTC191676

Company & Directors' Information:- K W INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U70102DL2011PTC224462

Company & Directors' Information:- A S M INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U70102DL2015PTC279049

Company & Directors' Information:- J V B INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U70102DL2015PTC283560

Company & Directors' Information:- A K S T INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U70109DL2012PTC236675

Company & Directors' Information:- M. A. INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45200DL2007PTC158810

Company & Directors' Information:- G S K INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45200DL2006PTC155120

Company & Directors' Information:- H V INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200DL2007PTC158234

Company & Directors' Information:- R. R. G INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200DL2007PTC170567

Company & Directors' Information:- B P M INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45200DL2008PTC179121

Company & Directors' Information:- M & H INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U80904DL2007PTC166303

Company & Directors' Information:- B H I INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U70101MP2012PTC029256

Company & Directors' Information:- S AND Y INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200MP2013PTC031382

Company & Directors' Information:- P V R N INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45400HR2010PTC040311

Company & Directors' Information:- C D INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U74900HR2007PTC037175

Company & Directors' Information:- R J S INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45201GJ2009PTC055941

Company & Directors' Information:- B R B INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45201GJ2008PTC053682

Company & Directors' Information:- B. R. INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45201GJ2008PTC054103

Company & Directors' Information:- T H D INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45200KL2012PTC032595

Company & Directors' Information:- J S INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45203GJ2003PTC042641

Company & Directors' Information:- A L E M INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U29308GJ2020PTC118118

Company & Directors' Information:- D H INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U45400MH2021PTC353332

Company & Directors' Information:- J B INFRASTRUCTURE PRIVATE LIMITED [Active] CIN = U64200GJ2021PTC121701

Company & Directors' Information:- A AND H INFRASTRUCTURE LIMITED [Strike Off] CIN = U45203MH1998PLC117368

Company & Directors' Information:- D L C INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45201PB2007PTC031022

Company & Directors' Information:- R S J INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45300DL2007PTC167583

Company & Directors' Information:- N K INFRASTRUCTURE PRIVATE LIMITED [Strike Off] CIN = U45200DL2006PTC156614

    Excise Appeal No. 51224 of 2018 (Arising out of Order-in-Appeal No. 15 (RK) CE/JPR/2017-18 dated 02.02.2018 passed by the Commissioner (Appeals), Central Excise, Jaipur)

    Decided On, 08 January 2020

    At, Customs Excise Service Tax Appellate Tribunal Principal Bench New Delhi

    By, THE HONORABLE JUSTICE: BIJAY KUMAR
    By, MEMBER AND THE HONORABLE JUSTICE: RACHNA GUPTA
    By, MEMBER

    For Petitioner: O.P. Bisht, Authorised Representative And For Respondents: S. Dass and Amit Jain, Advocates



Judgment Text


1. The Department has assailed the Order-in- Appeal No. 15/JPR/2017-18 dated 7th February, 2018, vide the present appeal. The facts in brief relevant for the purpose are that the respondent assessee M/s. Genus Power Infrastructures Ltd. are engaged in manufacture of electric energy meters and were availing the Cenvat Credit upon the duty paid thereof. During the course of audit, Department observed that the respondent, assessee has availed the Cenvat Credit of Rs. 88,51,546/- During the period from April 2012 to August, 2014 on the strength of ineligible documents i.e. endorsed invoices/Bill of Entries which amounts to contravention of rule 9 (1) of Cenvat Credit Rules, 2004. Resultantly, a show cause notice No. 673-75 dated 12/16 February, 2015 proposing the recovery of the said amount of Cenvat Credit alleging the same to have been wrongly availed, alongwith the interest at appropriate rate and the proportionate penalty. The said proposal was confirmed vide Order-in-Original No. 114/2016-17 dated 15.02.2017. The appeal thereof has been allowed vide order under challenge. Pursuant thereto Review Order dated 20 April, 2018 was passed requiring the Department to prefer an appeal before this Tribunal. Consequently, the Department is in appeal before this Tribunal.

2. It is submitted on behalf of the appellant/Department that Rule 9 of Cenvat Credit Rules, 2004 do not specify for endorsed invoices/Bill of Entries to be the relevant document for the purpose of claiming the cenvat credit. There is no denial that the assessee/respondent has availed the Cenvat Credit on the endorsed invoices. Hence, it is a case of definite violation of Rule 9 because of which the Cenvat Credit could not have been allowed to be availed, as was earlier held by original adjudicating authority. However, the Commissioner (Appeals) has given a contrary finding. The order is, accordingly, liable to be set aside.

3. While rebutting these arguments, ld. Counsel for the assessee-respondent has submitted that the respondent has taken Cenvat Credit on such inputs which have been received by them through their another unit located at Haridwar, Uttaranchal However, on the strength of the invoices/Bill of Entry, which were endorsed by Haridwar Unit in its favour.

4. It is submitted that in terms of Rule 9 (1) (a) and 9 (1) (c) of Cenvat Credit Rules an invoice and Bill of Entry are valid documents based on which a manufacturer of final product can avail credit. An invoice or Bill of Entry does not cease to be an invoice or Bill of Entry after endorsement, but remain as such. Learned Counsel has mentioned that the endorsed invoices had already been held to be a valid document under Rule 9/1 of Cenvat Credit Rules. Following decisions have been relied upon:-

1. CCE, Chandigarh vs. Stelko Strips Ltd., reported in 2010 (255) ELT 397 (P & H)

2. Uni Cast Pvt. Lot. Vs. CCE, Meerut reported in : 2016 (331) ELT 369 (All.)

3. Sona Koya Steering Systems Ltd. v. CCE reported in : 2013 (296) ELT 481 (Tri.-Del.)

4. International Tobacco Co. Ltd. v. CCE, Ghaziabad reported in 2018 (8) TMI 1170, CESTAT-Allahabad.

5. Alleging the grounds taken in the show cause notice to be based on assumptions and presumptions and that the ground taken in the appeal is the one, which is not alleged in the show cause notice issued to the appellant, that the order of Commissioner (Appeals) is prayed to be upheld and appeal is prayed to be dismissed.

6. After hearing the parties, we observe that the Cenvat Credit to the assessee-respondent has been denied for want of the eligible documents for the purpose. We observe that there is no denial about the receipt of the inputs/raw-material by the respondent-assessee in their factory from their another unit at Haridwar for those inputs/raw-material to be used in the manufacture of dutiable final product by the assessee-respondent. There is also no denial to the facts that liability towards Excise Duty on such final product has already been discharged by the appellant. Apparently and admittedly, under Rule 9 (1) an invoice and Bill of Entry are valid documents based on which a manufacturer of final product can avail credit. We observe from the rule that there is no stipulation about the said invoice or the Bill of Entry to not to be the endorsed. We further observe that the issue is no more res integra. The Hon'ble Supreme Court way back in the year 2008 when the previous rules of Modvat Cenvat Credit were prevalent for the purpose, has already held in the case of Union of India vs. Marmagoa Steel Ltd. reported as 2008 (229) ELT 481 (SC) as follows:-

"9. At this stage we may quote the provisions of Rule 52A and Rule 57G:

"RULE 52A. Goods to be delivered on an invoice. - (1) No excisable goods shall be delivered from a factory or a warehouse except under an invoice signed by the owner of the factory, or his authorised agent.

........................................."

"RULE 57G. Procedure to be observed by the manufacturer. - (1) Every manufacturer intending to take credit of the duty paid in inputs under rule 57A, shall file a declaration with the Assistant Collector of Central Excise having jurisdiction over his factory, indicating the description of the final products manufactured in his factory and the inputs intended to be used in each of the said final products and such other information as the said Assistant Collector may require, and obtain a dated acknowledgment of the said declaration.

(2) A manufacturer who has filed a declaration under sub-rule (1) may, after obtaining the acknowledgment aforesaid, take credit of the duty paid on the inputs received by him:

Provided that no credit shall be taken unless the inputs are received in the factory the cover of an invoice issued under Rule 52A, an AR-1, or Bill of Entry or any other document as may be prescribed by the Central Government by notification in the Official Gazette in this behalf evidencing the payment of duty on such inputs.
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10. On reading Rule 52A the position which emerges broadly is that the said Rule refers to eligibility for claiming MODVAT Credit, whereas Rule 57G refers to procedure to be observed by the manufacturer for taking credit for the duty paid on the inputs received by him. A bare reading of Rule 52A shows that no excisable goods shall be delivered from a factory or a warehouse except under an invoice signed by the owner of the factory or his authorised agent. Rule 52A, therefore, applies to a situation where goods are cleared from a factory or a warehouse to the place of assessee. For such a situation the proviso in Rule 57G stipulates that no credit shall be taken unless the inputs are received in the factory under the cover of an invoice issued under Rule 52A. However, that situation does not arise in this case for the simple reasons that the importer M/s. Essar Gujarat Limited had loaned the goods to the assessee (which transaction is not doubted in the show cause notice). Further the goods were transferred directly by the importer to the Unit of the assessee from the Port. Therefore, the goods never went to the manufacturing Unit of M/s. Essar Gujarat Limited. For such a situation the proviso to sub-rule (2) of Rule 57G states that the relevant document indicating payment of duty would be Bill of Entry."

7. Subsequently, there have been the decisions as already quoted by the ld. Counsel for the assessee. Hon'ble High Court, Allahabad in the case of Unicast Pvt. Ltd. Vs. CCE, Meerut reported in : 2016 (331) E.L.T. 369 (Allahabad) has quoted the findings of Hon'ble High Court of Madras in the case of CCE, Salem vs. M/s. Chemplast Sanmar Ltd. [2009 (239) ELT 398 (Mad.) that Modvat Credit cannot be denied to an assessee on a technical ground that the procedure prescribed for availment of credit was not followed at the material time.

8. Hon'ble Apex Court in Ichalkaranji Machine Centre Pvt. Ltd. v. Collector of Central Excise, Pune [2004 (174) E.L.T. 417 (S.C.)], the Supreme Court explained the object and scope of Modvat credit holding:-

"9. Modvat is basically a duty-collecting procedure, which aims at allowing relief to a manufacturer on the duty element borne by him in respect of the inputs used by him. It was introduced w.e.f. 1-3-1986. The said scheme was regulated under Rules 57A to 57J of Central Excise Rules, 1944. Rule 57A entitled a manufacturer to take instant credit of the central excise duty paid on the inputs used by him in the manufacture of the finished product, provided that the input and the finished product were excisable commodities and fell under any of the specified chapters in the tariff schedule. Under Rule 57G, every manufacturer was required to file a declaration before the jurisdictional Assistant Collector, declaring his intention to take Modvat credit after paying duty on the inputs. The object behind Rule 57A read with Rule 57G and Rule 57-I was utilization of credit allowed towards payment of duty on any of the final products in relation to manufacture of which such inputs were intended to be used in accordance with the declaration under Rule 57G. Rule 57-I referred to consequences of taking credit wrongly.

10. The object of the Modvat scheme was to reduce cost of final product by taking credit for the duty paid on the inputs."

9. It has also been clarified by the Hon'ble Supreme Court in the case of Madras Cements Ltd. Vs. Commissioner of Central Excise reported in : 2010 254 E.L.T. 3 (S.C.) that to avail the Modvat/Cenvat Credit an assessee has to satisfy the assessing authorities that the capital goods on which the credit has been availed have been utilized during the process of manufacture of the finished products. As already observed, there is no denial of the Department for the same. Thus, in the given circumstances, we are of the opinion that when admittedly the inputs/capital goods/raw-material has been transferred from one unit to another by making endorsement on the invoices and these transferred goods are used by recipient unit in manufacture of final product then such invoices can be taken as a valid document by said recipient unit for taking the Cenvat Credit irrespective of the fact that the invoice was issued in the name of transferring unit but has been endorsed in the name of recipient unit who is appellant in the present case. This view stands corroborated from the decision of this Tribunal in the case of CCE vs. Coimbatore Murugan Mills reported in : 2003 (160) E.L.T. 825.

10. Above all, the allegation of the show cause notice are pointing merely a procedural lapse. Hon'ble Supreme Court in case of Sambhaji vs. Gangabhai reported in: 2009 (240) E.L.T. 161 (S.C.) has held that all rules of procedures are handmaids of justice. Language employed by draftsman of procedural law may be liberal or stringent but object of prescribing procedure is to advance the cause of justice. It was held that no party should ordinarily be denied opportunity of participating in process of justice dispensation in an adversarial system. Procedural law is not to be a tyrant but a servant, not an obstruction but an aid to justice. A procedural prescription is the handmaid and not the mistress, a lubricant, not a resistant in the administration of justice. The endorsed invoice otherwise qualify the intent of the legislature in terms of proviso to Rule 9 (2) of CCR. In view of entire above discussion, we do not find any infirmity in the order of Commissioner (Appeals), wherein he has quoted as follows:-

"9. I find that it is not a case of the revenue that the inputs on which CENVAT credit has been availed were not received in the factory premises or were not used

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in the manufacture of the final product on which appropriate duty was paid. I also find that in case of CCE, Noida vs. Fles Industries Ltd. - 2004 (178) ELT 1029 (Tri.-Del.), Hon'ble Tribunal held that goods transferred from one factory to other factory of the same company by making endorsement on the invoices is a valid documents for taking CENVAT Credit under Rule 9 of the CC Rules, 2004, and in CCE vs. Coimbatore Murugan Mills : 2003 (160) ELT 825 (Tri. - Chennai), it was held that the inputs transferred to sister unit of the same parent unit on the basis of endorsed invoices issued by the sister unit proper and CENVAT Credit is admissible. In Akzo Nobel Coatings (I) Ltd. vs. CC Ex., Bangalore reported in : 2013 (290) ELT 108 (Tri.-Bang.), it was held that CENVAT Credit cannot be denied on endorsed Bill of Entry under Rule 9 of CENVAT Credit Rules, 2004. I further find that in CCCE vs. DNH Spinners : 2009 (16) STR (Tri.-Admd.), Twenty First Century Printers Ltd. vs. CCE - 2009 (234) ELT 277, it was held that substantive benefit cannot be denied on procedural grounds of endorsed documents, when there is no dispute of material having been received and used for manufacture of final product which were cleared on payment of duty." 11. The order accordingly is upheld and appeal stands dismissed.
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