{"id":110120,"date":"1995-11-24T00:00:00","date_gmt":"1995-11-23T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/hindalco-industries-limited-vs-collector-of-c-excise-on-24-november-1995"},"modified":"2017-04-10T13:08:14","modified_gmt":"2017-04-10T07:38:14","slug":"hindalco-industries-limited-vs-collector-of-c-excise-on-24-november-1995","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/hindalco-industries-limited-vs-collector-of-c-excise-on-24-november-1995","title":{"rendered":"Hindalco Industries Limited vs Collector Of C. Excise on 24 November, 1995"},"content":{"rendered":"
Customs, Excise and Gold Tribunal – Delhi<\/div>\n
Hindalco Industries Limited vs Collector Of C. Excise on 24 November, 1995<\/div>\n
Equivalent citations: 1996 (86) ELT 571 Tri Del<\/div>\n<\/p>\n
<\/pre>\n
ORDER<\/p>\n
 Jyoti Balasundaram, Member (J)<\/p>\n
1. The brief facts of the case are that the appellants herein are engaged in the manufacture of Aluminium and products thereof falling under Chapter 76 of the First Schedule to the Central Excise Tariff Act, 1985. During the course of manufacture of these products, aluminium dross, pot dug out material and furnace dug out material arise. The appellants were also availing of Modvat credit on the inputs of alumina and products thereof under Rule 57A of the Central Excise Rules, 1944. Classification lists claiming nil duty exemption on these three items in terms of Notification No. 19\/88, dated 1-3-1988 as amended, were filed by the appellants. The said notification stipulated that goods falling under Chapter 26 of the Schedule may be cleared at nil rate of duty provided that no credit of duty paid on the inputs used in the manufacture of the said goods has been taken under Rule 56A or 57A. Since the department was of the view that the appellants did not fulfil this condition as they had availed the benefit of Modvat credit on inputs used in the manufacture of aluminium dross, pot dug out material and furnace dug out material and cleared them without payment of duty, show cause notices were issued proposing recovery of duty and imposition of penalty.\n<\/p>\n
2. The appellants replied to the notices setting out the process of emergence of aluminium dross, pot dug out material and furnace dug out material. They contended inter alia that these items were not excisable goods and that the inputs on which Modvat credit was taken by them are … used in the manufacture of aluminium and products thereof and no input is used in the manufacture of aluminium dross, pot dug out material and furnace dug out material and hence they are not hit by the proviso to Notification No. 19\/88. They also cited the judgment of the Hon’ble Bombay High Court in the case of Indian Aluminium Company Ltd. v. A.K. Bandopadayay – 1980 (6, E.L.T. 146, wherein it was held that aluminium dross is not excisable and the judgment of the Hon’ble Supreme Court in the case of Swadeshi Polytex – 1990 (44) E.L.T. 794. The appellants also raised the plea of time bar in the demand for the period from 25-7-1991 to 31-3-[1992] (Appeal No. E-3019\/93-C).\n<\/p>\n
3.   The Adjudicating authority held that the items were excisable, holding that all the three items are in the nature of residues of metal or metal compounds which are covered under Chapter sub-heading 2620.00 of the Tariff. He also relied upon the HSN Explanatory Notes to Chapter Heading 2620. As regards the case laws cited by the appellants, he held that these judgments were rendered in   the context of the old Tariff and hence not applicable in the context of Central Excise Tariff Act, 1985 in the purview of which the goods in question were excisable goods having distinct name, character and use and having commercial\/industrial value. He also held that the appellants were not entitled to the benefit of Modvat credit due to non-fulfilment of condition prescribed in Notification No. 19\/88, treating the three items in dispute as complete excisable finished products. He held that the extended period of limitation was available to the department as the appellants were guilty of suppression of declaration of the three disputed items as final products in which the inputs on which the credit was availed, were used. He therefore, confirmed the duty demands and imposed penalties as detailed below:\n<\/p>\n
  ——————————————————————————\n<\/p>\n
Sl.  Appeal No.    Period of Dispute   Date of SCN Amount         Penalty\nNo. \n------------------------------------------------------------------------------\n1.   E\/3019\/93-C   25-7-1991 to        3-2-1993     20,02,457\/-   5,00,000\/-\n                   31-3-1992\n\n2.   E\/597\/94-C    January 1993 to     23-3-1993 &  10,24,6387-   5,000\/-\n                   April 1993          26-5-1993\n\n3.   E\/595\/94-C    April 1992 to       25-9-1992    22,07,159.62  5,000\/-\n                   December 1992       22-9-1992 \n                                       13-11-1992 \n                                       20-1-1993\n\n4.   E\/596\/94-C    CL effective        25-9-1992\n                   25-7-1991 &         22-9-1992\n                   1-3-1992            13-11-1992\n                                       20-1-1993\n\n5.   E\/594\/94-C    CL effective from   -\n                   25-2-1993\n\n6.   E\/599\/94-C    CL effective from\n                   25-2-1993\n\n7.   E\/2061\/94-C   July 1993 to        26-10-1993    7,20,442.70   5,000\/-\n                   Sept 1993\n\n8.   E\/2059\/94-C   May 1993 to         20-7-1993     4,62,637.38   5,000\/-\n                   June 1993\n\n \n\n<\/pre>\n
4.   Shri V. Sridharan, learned Counsel appearing on behalf of the appellants, submits that the appellants are engaged in the manufacture of aluminium products such as aluminium ingots, billets, wire rods, etc. and rolled and extruded products therefrom namely sheets, strips, profiles etc. They obtained bauxite ore from their own mines and extruded alumina therefrom using various chemicals. Molten aluminium is prepared from alumina by reduction process and the molten aluminium is siphoned off into crucibles. From there, the molten aluminium is taken to the re-melting and casting shop, poured into oil fired melting furnace, into which aluminium scrap, alloy ingots etc. are also added and allowed to melt. The melt is then subjected to fluxing and degassing and then transferred to holding furnace. In the melting furnace and holding furnace, the top layer is exposed to the atmosphere and gets oxidised and a thin layer\/film is thus formed which is removed by manual skimming operation. The learned Counsel submits that the refuse or skimmed material so removed is known as dross. Certain fluxes are added in the furnace to help in the collection of this dross. The second item on which duty has been demanded in these appeals is pot dug out material which is the lining material of the pot cells along with bath solution which remains in the pot cells whenever there is failure of pot cells and this item consists mainly of carbonaceous material and is not a manufactured item. Furnace dug out material is the lining material left out in the furnace after corrosion of the lining of refractory bricks and this material is dug out before relining of the furnace is carried out and this is not a manufactured item. The learned Counsel contends that aluminium dross is not an excisable commodity as held by the Tribunal vide Order No. 44\/87 dated 23-1-1987 and Order No. 381\/88 dated 17-5-1988 in the appellants own case. The recent judgment of the Hon’ble Supreme Court in the case of Union of India v. Indian Aluminium Co. Ltd.<\/a> -1995 (77) E.L.T. 628 has confirmed the order of the Hon’ble Bombay High Court in the case reported in 1980 (6) E.L.T. 146 holding that aluminium dross and skimmings are not goods or marketable commodity which can be subjected to the levy of Excise. The learned Counsel contends that even though the judgment of the Hon’ble Supreme Court was rendered in the context of the First Schedule to the Central Excises and Salt Act, 1944 as it stood prior to 1-3-1986, the ratio would continue to apply even in the context of the Schedule to the Central Excise Tariff Act, 1985 as firstly there is no material change in the definition of manufacture as contained in Section 2(f) of the Central Excises and Salt Act, 1944 prior to 1-3-1986 and thereafter, and secondly the Charging section i.e. Section 3 continues to remain the same even after the introduction of new Central Excise Tariff Act, 1985. His next submission is that aluminium dross is nowhere specified in the Tariff and Heading 2620.00 only covers ash and residues containing metal or metal components. Aluminium dross is not a residue and hence cannot be covered by this Heading.\n<\/p>\n
5. The next submission of the learned Counsel is that the proviso to Notification No. 19\/88 is not applicable to the goods and in support of this contention, he relies upon the judgment of the Bombay High Court in the case of Indian Aluminium Co. -1980 (6) E.L.T. 146 wherein the benefit of proforma credit was extended to aluminium contained in aluminium dross arising in the course of its manufacture. The Revenue had sought to rely upon the proviso to Sub-rule (2) of Rule 56A to deny proforma credit, treating aluminium dross as finished excisable goods and since these were exempt from duty, credit was not available on any material or component parts used in its manufacture. However, the High Court, apart from holding that dross is not goods, further held that aluminium sheets were the end product or finished product and not dross and skimmings which were merely the refuse of skimmings drawn out of the manufacture of the finished product. The learned Counsel submits that the Adjudicating Authority has wrongly distinguished the judgment of the Bombay High Court on the ground that the dross and skimmings in that case were non-excisable whereas in the impugned order, they have been held to be excisable commodities because the conclusion of the High Court that dross and skimming are not finished excisable goods, was based upon the reasoning that only aluminium sheets can be considered as finished excisable goods. The learned Counsel also relies upon the judgment of the Hon’ble Supreme Court in the case of Swadeshi Polytex -1989 (44) E.L.T. 794 (SC), upholding the claim of the assessee for set off of duty paid on ethylene glycol under Tariff Item 68 used as an input in terms of Notification No. 201 \/79 which had been denied by the department on the ground that methanol which emerged in the process of manufacture, was the finished excisable goods cleared without payment of duty. The learned counsel also drew our attention to relevant Modvat rules namely Rules 57A, 57D and 57F to support his contention that the Scheme of Modvat is to provide credit on input vis-a-vis the finished excisable goods (final products) and does not contemplate use of inputs in the manufacture of any waste etc. or utilisation of input credit towards duty leviable on waste. He submits that but for Rule 57F(3)(ii), credit of input duty would not have been allowed to be utilised towards payment of duty on waste. Our attention has been drawn by the learned Counsel to ‘Rule 57D (i) which provides that credit of duty allowed in respect of any inputs shall not be denied or refused on the ground that part of the inputs is contained in any waste, refuse or by-product arising during the manufacture of the final product whether or not such waste etc., is exempt from duty or chargeable to nil rate of duty or is not specified as a final product under Rule 57A. Lastly, the learned Counsel submits that the show cause notice in E\/3019\/93-C is barred by limitation as the entire demand is beyond the period of 6 months. The Proviso to Section HA cannot be invoked since every aspect was within the knowledge of the department. The appellants did not declare dross in their declaration filed under Rule 57A because dross is waste and not a final product. Classification lists have been filed for dross for several years and the classification list effective from March, 1988, July, 1991 and March, 1992 relating to dross have been approved by the department by extending the benefit of Notification No. 19\/88, RT 12 returns have been duly filed for aluminium dross under nil rate of duty and duly assessed; GP1s issued for aluminium dross for nil rate of duty were filed with the RT 12 returns and Modvat declarations have been filed and RG 23A Part I and II accounts had also been regularly maintained by the appellants and hence the department was fully aware of the availment of Modvat by the appellants. Hence, the charge of suppression cannot be levelled against them.\n<\/p>\n
6. Replying to the arguments of the learned Counsel, Sh. K.K. Dutta, learned DR submits that aluminium dross, pot dug out material and furnace dug out material are excisable goods covered under sub-heading 2620.00 as they are residues arising in the course of manufacture of aluminium and products thereof. He refers to Note 3 to Chapter 26 and submits that since the residues are admittedly used in industry for extraction of metals, they are excisable goods. In view of the specific coverage of such residues in Chapter 26, the judgment of the Hon’ble Supreme Court in the case of Collector of Central Excise v. Indian Aluminium Co. – 1995 (77) E.L.T. 268, which was rendered in the context of old Tariff is not applicable in the context of the new Tariff. He cites the decision of the Tribunal in the case of D.K. Electricals -1994 (74) E.L.T. 272, holding that conversion of GI steel wires falling under sub-heading 7217.90 into PVC coated insulated wires falling under sub-heading 8544.00 amounts to manufacture in terms of Section 2(f) of the Central Excises and Salt Act, 1944, in support of the argument that since the new Tariff contains an entry for residue containing metals or metal compounds (other than residue from the manufacture of iron or steel), the items in disputes are undoubtedly excisable goods. He draws our attention to paragraph 13 of the impugned order wherein the Collector has held that the judgment of the Hon’ble High Court in the case of Indian Aluminium Co. (supra) is not applicable in the present case as the Court had held that dross and skimmings arising in the course of manufacture of aluminium were non-excisable in the context of the old Tariff, where in the context of new Tariff, they were clearly leviable to excise duty. He also invites our attention to paragraph 12 of the impugned order and submits that the words “finished goods” used in Rule 57 means goods which are fully finished or completely manufactured i.e. goods in the manufacture of which all processes are completed and nothing is remaining. He submits that scope of Rule 57A is very wide and even covers waste. Therefore, since the appellants used inputs in the manufacture of dross, pot dug out material and furnace dug out material, they are hit by the proviso to Notification 19\/88. On the issue of time bar, he relies upon the findings contained in para 14 of the impugned order wherein the non-declaration of aluminium dross etc. i.e. final products in which the inputs on which credit was availed were used and similar non-declaration in the classification lists has been held to amount to suppression on the part of the appellants.\n<\/p>\n
7. We have carefully considered the submissions of both the sides. The process of manufacture of aluminium and the process of emergence of aluminium dross, Pot dug out material and furnace dug out material has already been set out in paragraph 4 of this order while recording the submissions of the learned Counsel for the appellants. In the case of Indian Aluminium Co. reported in 1995 (77) E.L.T. 268 (SC), the Hon’ble Supreme Court has held that aluminium dross and skimmings are not ‘goods’ or marketable commodities which can be subjected to the levy of Excise. At the commencement of the judgment, the process of manufacture of aluminium products and emergence of dross and skimmings has been set out as under :\n<\/p>\n
 “The respondents in all these appeals manufacture aluminium products such as aluminium sheets, aluminium shapes, aluminium angles, etc. out of aluminium lingots. In the process of manufacture, at the stage of processing, dross and skimming arise and accumulate in the furnace in the shape of ashes as a result of oxidisation of metal. These ashes are formed mainly during the melting down of aluminium ingots and, to some extent, during subsequent treatment and holding operation of molten baths in the furnace. Dross consists mostly of oxides, non-metallic material and other foreign material which separates or dorms during melting and holding operations, and finally accumulates on the surface of the molten bath. It has to be removed. Skimmings are mostly thin oxide layers obtained by skimming a molten bath prior to metel transfer on casting. The skimming operation is essential to the manufacture process. Dross and skimmings, according to the assessees, represent a process-loss or a melt loss. Aluminium dross and skimmings contain a certain amount of metal from which they come. But they lack not only metal body but also metal strength, formability and character. Such dross and skimmings are, therefore, distinct from scrap which is a metal of as good a quality as the prime metal from which it arises.”\n<\/p>\n
The findings of the Court as contained in paragraph 13 which is reproduced for easy reference:\n<\/p>\n
“It is also not possible to accept the contention of the appellants that aluminium dross and skimmings are ‘goods’ or marketable commodity which can be subjected to the levy of excise. Undoubtedly, aluminium dross and skimmings do arise during the process of manufacture But these are nothing but waste or rubbish which is thrown up in the course of manufacture. The term ‘dross’ is defined in The New Shorter Oxford English Dictionary as :\n<\/p>\n
Dross:\n<\/p>\n
Dregs.., (1) Impurities separated from metal by melting the scum which forms on the surface of molten metal…(2) Foreign matter mixed with anything…(3) Refuse, rubbish, worthless mater especially as contrasted with or separated from something of value”\n<\/p>\n
The ASM Metals Reference Book (2nd Edition 1983) produced by the American Society for Metals defines ‘dross’ as follows :\n<\/p>\n
  ‘The scum that forms on the surface of molten metals largely because of oxidation but sometimes because of the rising of impurities to the surface’<\/p>\n
McGraw Hill Dictionary of Science and Engineering (1984 Edition) defines it as :\n<\/p>\n
“An impurity, usually an oxide, formed on the surface of molten metal”\n<\/p>\n
Dross and skimmings may contain some small percentage of metal. But dross and skimmings are not metal in the same class as waste or scrap. It may be possible to recover some metal from such dross and skimmings. They can, therefore, be sold. But this does not make them a marketable commodity. As learned Single Judge of the Bombay High Court has pointed out, even rubbish can be sold. Everything however, which is sold is not necessarily a marketable commodity as known to commerce and which it may be worthwhile to trade in. Learned Single Judge of the Bombay High Court, therefore rightly came to the conclusion that the proviso to Rule 56A was not applicable as aluminium dross and skimmings are not excisable goods.”\n<\/p>\n
It is relevant to note that the Supreme Court also disposed of connected appeals including that of the appellants herein.\n<\/p>\n
8. We see strong force in the contention of the appellants that even though this judgment was rendered in the context of the first Schedule to the Central Excises and Salt Act, 1944 as it stood prior to 1-3-1986, the ratio thereof would continue to apply even in the context of the present Tariff as (a) there is no material change in the definition of manufacture as contained in Section 2(f) of Central Excises and Salt Act, 1944 prior to 1-3-1986 and thereafter and (b) Entry in the Tariff viz. Pleading 26.20 covers “Ash residues’ other than from the manufacture of iron and steel containing metals or metallic compounds is not per se sufficient for determining the excisability without determining whether the items came into existence as a result of manufacture, as held by the Hon’ble Supreme Court in the case of Bhor Industries Ltd. v. Collector of Central Excise<\/a> -1989 (40) E.L.T. 280 (SC). The Supreme Court has held therein that, in order to be goods, an article must be something which can ordinarily come to the market and is brought for sale and must be known to the market as such. The Court held that the essential ingredient for levying duty of Excise is that there should be manufacture of goods and simply because a certain article falls within the Schedule, it would not be dutiable under Excise law if the said article is not ‘goods’ known to the market. Marketability therefore, is an essential ingredient for dutiability under the Schedule to the Central Excise Tariff Act, 1985. The judgment of the Hon’ble Supreme Court in the case of Indian Aluminium Company (supra) is applicable on all fours to these appeals and hence following the ratio thereof, we hold that the aluminium dross, Pot dug out and Furnace dug out material are not excisable goods and set aside the duty demands. For the same reason, we also set aside the penalties imposed upon the appellants. [The decision in the D.K Electrical Industries case – 1994 (74) E.L.T. 272, cited by the learned DR is distinguishable from the facts of this case, as it has been held therein that the process of insulation of bare G.I. wires by coating with PVC amounts to manufacture.] In view of our finding that the items in dispute are not liable to Excise duty, we are not required to consider the submissions relating to Notification No. 19\/88 and the Modvat rules.\n<\/p>\n
9. Since we have held that the disputed items are not ‘goods’ within the meaning of Central Excises and Salt Act, 1944, their non-declaration as final products in the declaration filed under Rule 57G and their non-delcaration in the classification list, cannot be held to amount to suppression on their part, warranting the applicability of the extended period of limitation. We therefore, hold that the demand for the period from 25-7-1991 to 31-3-1992 (E\/A No. 3019\/93-C) is barred by limitation. In the result, we hold that no duty can be levied on the three items covered in all the above appeals and further held that the demand in E\/Appeal No. 3019\/93-C is barred by limitation. Accordingly, we set aside the duty demands and penalties and allow the appeals with consequential relief, if any, due to the appellants.\n<\/p>\n
 S.K. Bhatnagar, Vice President <\/p>\n
10. With due respects to my learned colleagues, my views and orders are as follows :-\n<\/p>\n
11.   I observe that the amendment of the Central Excises Act and the introduction of new tariff has made a substantial difference in many areas including those relating to ‘manufacture’ and ‘goods’.\n<\/p>\n
12.   The definition of manufacture as given in Section 2(f) has undergone many changes from time to time and after the latest change with which we are concerned, it reads as follows :-\n<\/p>\n
\"Section 2(f):    \"Manufacture\" includes any process,-\n  \n\n(i) incidental or ancillary to the completion of a manufactured product; and\n \n\n<\/pre>\n
(ii) which is specified in relation to any goods in the Section or Chapter notes of the Schedule to the Central Excise Tariff Act, 1985 (5 of 1986) as amounting to manufacture, and the word ‘manufacture’ shall be construed accordingly and shall include not only a person who employs hired labour in the production or manufacture of excisable goods, but also any person who engages in their production or manufacture on his own account.”\n<\/p>\n
13.   As per the Central Excise Tariff Act, 1985 “The rates at which duties of excise shall be levied under the Central Excises and Salt Act, 1944 (1 of 1944) are specified in the Schedule.\n<\/p>\n
14.   The Central Excise duty is a tax levied with reference to ‘goods’ and relevant part of Section 3 of the Central Excises and Salt Act reads as follows :-\n<\/p>\n
 “Section 3. Duties specified in the Schedule to the Central Excise Tariff Act, 1985 to be levied. – (1) There shall be levied and collected in such manner as may be prescribed duties of excise on all excisable goods other than salt which are produced or manufactured in India and a duty on salt manufactured in, or imported by land into, any part of India as, and at the rates, set forth in the Schedule to the Central Excise Tariff Act, 1985”.\n<\/p>\n
The words ‘set forth’ in the Schedule to the Central Excise Tariff Act, 1985 are significant and refer to not merely the rates but also the items with reference to which the duty is required to be charged and which are therefore, mentioned in the headings or sub-heading, including those which are deemed to be ‘goods’ for the above purpose, unless proved otherwise.\n<\/p>\n
15.   As a matter of fact, the deeming fiction has been utilized in respect of a number of things and processes virtually chapter after chapter throughout the Schedule drawing sustenance apparently from Section 2(f)(ii). In view of this situation, we have to keep the above aspects in mind while attempting to apply the Tribunal’s orders or Courts’ judgments passed with reference to pre-amendment Act or the older Schedule.\n<\/p>\n
16.   In the present case, Chapter 26 contains Note 3 which reads as follows:-\n<\/p>\n
CHAPTER 26<\/p>\n
“3. Heading No. 26.20 applies only to ash and residues of a kind used in industry either for the extraction of metals or as a basis for the manufacture of chemical compounds of metals.”\n<\/p>\n
 ——————————————————————————\n<\/p>\n
Heading    Sub-heading   Description of goods\n------------------------------------------------------------------------------\n26.20      2620.00       Ash and residues (other than granulated slag),\n                         scalings and other waste from the manufacture of\n                         iron or steel\"\n------------------------------------------------------------------------------\n\n \n\n<\/pre>\n
The above note and entry have been incorporated knowing fully well that the ash and residue only arise during the process of manufacture and are not ‘manufactured’ in the normal sense of the term. This shows that Ash or residues of a type covered by Chapter Note 3, have to be considered as deemed goods by way of legal fiction. Any other view would render this entry and this chapter note redundant.\n<\/p>\n
17.   In the instant     however, no duty is leviable on such Ashes or residues because Notification No. 19\/88-CE, dated 1-3-88 reads as follows:-\n<\/p>\n
 “In exercise of the powers conferred by Sub-rule (1) of rule 8 of the Central Excise Rules, 1944, the Central Government, hereby exempts goods falling within Chapter 26 of the Schedule to the Central Excise Tariff Act, 1985 (5 of 1986), from the whole of the duty of excise leviable thereon which is specified in the said Schedule”.\n<\/p>\n
18.   Insofar as Rule 57A is concerned, the provisions thereof only “apply to such finished excisable goods (hereinafter referred to as the “final products”) as the Central Government may, by Notification in the Official Gazette specify in this behalf.”\n<\/p>\n
19.   Dross and skimming or ashes, deemed to be goods, as per legal fiction cannot, however, be considered as ‘finished’ products by any stretch of imagination. They are not deliberately manufactured and none of the processes or activities are designed to produce them but they arise unavoidably due to chemical and technical or technological reasons during the course of manufacture of the ‘finished excisable goods’. Hence, it was not necessary to make any declaration under 57A about them. Not only that, the Modvat taken with reference to finished excisable goods could not be disallowed or reduced on account of such ash or residues because de facto they remain in the nature of waste, refuse or by-product, as the case may be, and therefore, Rule 57D comes to the rescue of the assessees.\n<\/p>\n
20.   In view of the above observations and findings, neither any duty is demandable nor any penalty is imposable.\n<\/p>\n
21.   I, therefore, agree with the findings of my learned colleagues to the extent that the fact of their non-declaration as final product under Rule 57G does not amount to suppression on their part. Their non-declaration in the classification list also does not amount to suppression as the issue was arguable and could at best be considered as a matter of difference of opinion or interpretation and did not amount to an act to defraud the Government. Therefore, I agree with my learned colleagues’ observations regarding time-bar.\n<\/p>\n
22.   Accordingly, I also agree that the demands and penalties are required to be set aside and the appeals are required to be allowed with consequential relief, if any, due to the appellants.<\/p>\n","protected":false},"excerpt":{"rendered":"
Customs, Excise and Gold Tribunal – Delhi Hindalco Industries Limited vs Collector Of C. Excise on 24 November, 1995 Equivalent citations: 1996 (86) ELT 571 Tri Del ORDER Jyoti Balasundaram, Member (J) 1. The brief facts of the case are that the appellants herein are engaged in the manufacture of Aluminium and products thereof falling […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[41,33],"tags":[],"class_list":["post-110120","post","type-post","status-publish","format-standard","hentry","category-customs-excise-and-gold-tribunal-delhi","category-tribunal"],"yoast_head":"\nHindalco Industries Limited vs Collector Of C. 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