{"id":78931,"date":"1986-06-13T00:00:00","date_gmt":"1986-06-12T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/h-m-m-limited-vs-collector-of-central-excise-on-13-june-1986"},"modified":"2015-12-26T21:02:21","modified_gmt":"2015-12-26T15:32:21","slug":"h-m-m-limited-vs-collector-of-central-excise-on-13-june-1986","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/h-m-m-limited-vs-collector-of-central-excise-on-13-june-1986","title":{"rendered":"H.M.M. Limited vs Collector Of Central Excise on 13 June, 1986"},"content":{"rendered":"
Customs, Excise and Gold Tribunal – Delhi<\/div>\n
H.M.M. Limited vs Collector Of Central Excise on 13 June, 1986<\/div>\n
Equivalent citations: 1986 (9) ECC 119, 1986 (8) ECR 254 Tri Delhi, 1987 (29) ELT 608 Tri Del<\/div>\n<\/p>\n
<\/pre>\n
ORDER<\/p>\n
 G. Sankaran, Vice-President <\/p>\n
1 This is an appeal directed against order No. 196\/84(G) dated 1.12.84 passed by the Collector of Central Excise (Appeals), Madras, dismissing the appeal filed by M\/s. Hindustan Milk Food Manufacturers Ltd., Dowleswaram (to be referred to hereinafter as “HMM”, for brevity’s sake) against Order No. 19\/84 dated 17-8-1984 passed by the Assistant Collector of Central Excise, Rajahmundry.<\/p>\n
2.     The facts of the case,  briefly  stated, are that  HMM  are engaged in  the  manufacture of milk foods which fall for classification as ”Prepared or Preserved Foods” under item No. 1B of the First Schedule to the Central Excises and Salt  Act,   1944 (GET,  for brevity’s sake). One of the principal inputs   for   manufacture   of   milk   foods   is   barley   malt   falling   under   item No.  68  CET.   HMM   used  to  receive  duty-paid  barley  malt  and utilize the same in the manufacture of prepared or preserved foods, namely, ‘Horlicks’, ‘Happiness’   etc.   HMM   were    availing   of the   facility   of   set   off   of   the duty paid  on  barley  malt  towards payment of Central Excise duty on the finished   goods   in   terms  of   Central   Excise   Notification   No.  201\/79   dated 4.6.79.   They   had   filed   the   prescribed   declaration   with   the   Jurisdictional Superintendent for availing themselves of the procedure of set-off.\n<\/p>\n
3.     HMM   has   two  factories  –   one   at   Nabha   (Punjab)   and   the  other at    Rajahmundry   (Andhra   Pradesh)   –    manufacturing   the   aforesaid   milk foods.   Except   for   some   small   quantities   cleared   from   these   factories packed   in   unit   containers,   the   goods   are   despatched   to   several   packing stations located at different places where they are packed in unit containers and cleared. The movement of the goods from the Rajahmundry factory (with which we are concerned) to the packing stations is regulated under Central Excise Rule 56B which lays down a “special procedure for removal in bond of semi-finished goods for certain purposes”. Duty is not required to be paid on the removal of the goods in bulk to the packing stations. They are packed into unit containers at the packing stations and cleared on payment of duty under item 1B of the GET.\n<\/p>\n
4. Barley malt, a commodity falling under item 68 GET, is one of the principal inputs for the manufacture of the subject milk foods. Central Excise Notification No. 201\/79 exempts all excisable goods in the manufacture of which duty paid inputs falling under item 68 CET are used, to the extent of the duty already paid on such inputs. The Superintendent of Central Excise,; Rajahmundry considered that, in terms of Notification No. 201\/79, HMM was entitled to avail themselves of the credit of the duty already paid on the inputs (barley malt) only to the extent of the duty paid on the quantity of barley malt used in the manufacture of the quantity of packed horlicks cleared from the Rajahmundry factory on payment of duty and not, as HMM had done, to avail of the full amount of duty paid on barley malt brought into the factory towards payment of duty on the packed horlicks cleared on payment of duty. On the basis, he issued a notice dated 14.3.84 to HMM calling upon them to show cause why the excess amount of credit of duty wrongly availed of during the period 15.9.83 to 14.3.84 amounting to Rs. 13,37,432.95 should not be disallowed, demanded and recovered from HMM in terms of para 4 of the Appendix to Notification No. 201\/79 read with Section 11A of the Central Excises & Salt Act. In due course, after holding adjudication proceedings, the Assistant Collector, Rajahmundry passed an order on 17.8.84 confirming the aforesaid demand for duty. He did not accept HMM’s contention that there was no requirement of exact co-relation on the input (malt) with the output (Horlicks) and they were, therefore, entitled to utilise the full extent of credit of the input duty towards payment of the duty on packed Horlicks. The Assistant Collector held that utilisation of the credit had to be limited to the extent the input was used in the quantity of Horlicks cleared on payment of duty.\n<\/p>\n
5.     Aggrieved with this order, HMM filed an appeal which was disposed of by the Collector (Appeals), Madras by his order dated 1.12.84. In rejecting the appeal, the Collector held that HMM were not eligible to take credit of the duty paid on barley malt used in the manufacture of Horlicks removed without payment of duty in terms of Rule 56B to their packing stations. It is this order which is now under challenge before us.\n<\/p>\n
6.     We  have  heard  Sri  D.B.  Engineer,  Advocate,  assisted by Sri  M.P. Baxi   and   A.C.   Gulati,   Advocates  for  HMM   and Smt.   Dolly  Saxena,   SDR, for the respondent.\n<\/p>\n
7.     Though  Sri   Engineer initially addressed  some arguments  in  support of   his   contention   that   credit   of   input   duty   earned   at   the  Rajahmundry factory  could  be  utilised  towards  payment  of  duty  on Horlicks (removed under   Rule   56B   from   the   said   factory   to   the   packing   stations   located elsewhere,  such  removals  being  without  payment of   duty)  packed at  the packing   stations   and   cleared   therefrom   on  payment   of   duty,  he gave  up this  contention   and  narrowed  down  the  dispute  to this : Could the entire credit of input duty be utilised towards payment of duty on Horlicks cleared on   payment   of   duty  from   the  Rajahmundry  factory? Though, part  of  the input   may   have   been   used   in   the   manufacture   of   Horlicks   despatched in bulk  to  the  packing stations? The contention was that it could be so utilised  without   any  co-relation   between   the   input   used  and x the  output cleared. Utilisation would not be restricted to the input duty on the proportionate quantity of input used in the manufacture of Horlicks cleared on payment of duty from the Rajahmundry factory as the department has held.\n<\/p>\n
8.     In  support  of   his  stand  that   co-relation  between   the input  and the   output   was   unnecessary,   the   following   decisions   were   cited   by   Sri Engineer:\n<\/p>\n
(a)    Tribunal's decision in Paper Products Ltd., Bombay v. CCE, Bombay 1984 (18) EX-.T. 507 (Tribunal)     1984 ECR 2080\n \n\n(b)    Madras High Court judgment in E.I.D.   Parry   (India)   Ltd.,   Madras   v.   Govt.   of  India  and  Ors. 1979 Cen Cus 370 D\n \n\n(c)    Tribunal's decision in Bajaj Tempo Ltd., Pune v. CCE, Pune 1984(16) E.L.T. 294 (Tribunal)\n \n\n(d)    Tribunal's decision in CCE, Bhubaneswar   v.   Titaghur   Paper   Mills     1985(21)   E.L.T.  901 (Tribunal)\n \n\nIt was also urged that Notification No. 201\/79 was of a very wide amplitude and, therefore, a broad and liberal construction should be placed therein. Two unreported decisions of this Tribunal which were against the appellant were also referred to. These are :\n  \n\n(a)    Order   No.   759\/84   C  dated   15.10.84   in  Appeal  No.   ED  (SB) (T) A.No.  484\/81-C  -  Madras  Rubber  Factory,  Madras V. CEE, Madras.<\/a>\n \n\n(b)   Order No. 138\/85 dt. 1.2.85 in Appeal No. ED(SB) (T) A.No.1143\/81-C    Madras   Rubber   Factory   Ltd.,   Madras   v.  CCE,  Cochin which followed Order No. 759\/84 C.\n \n\nHowever, Sri Engineer submitted that the facts of these two cases were different since, unlike in the instant case, transfer of credit from one factory to another was involved in the MRF case, and hence, those decisions would have- no application. Also, the Tribunal decision in Vikrant Tyres V. CCE, Bangalore, 1985 (21) ELT 620 which was against the stand of HMM was referred to but sought to be distinguished on the basis of the facts therein.\n \n\n9.     Replying on behalf of the respondent, Smt. Saxena, SDR, submitted that   exemption   Notification   201\/79   gave   only   a   limited   concession   i.e., to the  extent  of  the  duty paid  on  the  input  used  in  the  manufacture  of the output. In this view, the entire credit of the input duty was not available    for   utilisation.   She   refuted   Shri   Engineer's   contention   that   such utilisation was permissible under Rule 56A. Smt. Saxena placed sole reliance on Notification No. 201\/79. She did not make any submissions with reference to the case law cited by Shri Engineer.                   \n \n\n10.   We  have  carefully   considered   the submissions before  us.  Notification No. 201\/79 dated 4.6.79 reads as follows :\n<\/pre>\n
 “In exercise of the powers conferred by Sub-rule (1) of 8 of the Central Excise Rules, 1944, and in supersession of the notification of the Government of India in the Ministry of Finance (Deptt. of Revenue) No. 178\/77 Central Excises, dated the 8th June, 1977, the Central Government hereby exempts all excisable goods (hereinafter referred as “the said goods”), on which the duty of excise is leviable and in the manufacture of which any goods falling under item No. 68 of the First Schedule to the Central Excises and Salt Act, 1944 (1 of 1944) (hereinafter referred as “the inputs”) have been used from so much of the duty of excise leviable thereon as is equivalent to the duty of excise already paid on the inputs”.\n<\/p>\n
The aforesaid exemption is subject to the observance of the procedure set out in the appendix to the notification. The portions of the appendix relevant for the present purpose are :\n<\/p>\n
 “Clause 2 : A manufacturer may take credit of the duty already paid on the inputs which are received by him after submitting the declaration, and utilise such credit for payment of duty of excise on the said goods”. Clause 9 : (a) The Credit of duty taken in respect of any inputs may be utilised towards payment of duty on any said goods for the manufacture of which such inputs were declared by the manufacturer to be brought into the factory, or where such inputs are cleared from the factory as such, on such inputs”.\n<\/p>\n
The contention of the learned Counsel for the appellants is that a combined reading of these provisions would lead to the conclusion that the entire credit of the duty already paid on the input could be utilised towards payment of duty on the finished product without any co-relation of the input and output. In other words, the credit available for such utilisation is not limited to the duty (suffered by the quantity of the input as is used in the manufacture of the quantity of finished product under assessment and clearance. The entire credit could be utilised. The contention of the learned Senior Departmental Representative, on the other hand, is that credit of the input duty could be utilised only to the extent of the duty suffered by the quantity of the input utilised in the manufacture of the finished product under assessment and clearance.\n<\/p>\n
11.   A prima facie reading would appear to suggest that Sri Engineer’s contention is not correct.  This is because    the operative part of the notification   confers   exemption   on   the   finished   product   from   so   much  of  the duty   of   excise   leviable   thereon   as   is   equivalent   to   the   duty   of   excise already   paid   on   the   inputs   (underlining   ours).   The   word   ‘equivalent’   is not   without   significance.   It   means   and   implies   that   when   a  consignment of   the   finished   product   is   presented   for   assessment  (or   is   self-assessed), the   duty   normally   leviable   is   to   be   reduced   by   an   extent   equal   to   the duty already paid on the input. There must, therefore be some co-relation, though   not   necessarily   an   exact   co-relation,   between   the   input   and   the out-put.   The   procedure   laid   down   in   the   Appendix   to   the   Notification is   apparently   a   measure   of   facilitation   to   enable   easy   availment   of   the benefit   of   the  exemption,  but  the  procedure  cannot,   for  obvious  reasons, have the effect of increasing the quantum of exemption itself which would appear  to  be  the  result  if  Sri  Engineer’s  contention were to be accepted as correct.\n<\/p>\n
12.   We   now   proceed   to   discuss   the   authorities   referred   to   by   the learned   Counsel   for   the   appellants.   In   Bajaj   Tempo   Ltd.,   Pune   v. CCE, Pune 1984 (16) ELT 294 (Tribunal). The tribunal held  that   if  there  is substantial  compliance with  the procedure prescribed in   the   Appendix    to   Notification   No.   201\/79,   the   appellants   would   not be   debarred   from   availing   themself   of   the   proforma   credit   procedure even   after   notification   No.   166\/79   was   rescinded   on   1.8.80.   The   import of   the   decision   is   that technicalities cannot   have   the   result   of   negating relief   under   the   notification    if   there   is   substantial   compliance   with   the procedure.   We   do  not   see  the  relevance  of  this  decision   to  the  facts  of the present case.\n<\/p>\n
13. In Collector of Central Excise, Bhuvaneshwar v. Titagarh Paper Mills – 1985 (21) ELT 901 (Tribunal), the Tribunal has held that a raw material is a material that is put into the manufacturing system to help in the formation of the finished product. There is no authority to say that an input or raw material must go directly into the finished product. As long as it is consumed and utilised in a way that results or helps in the production or manufacture of the article in which the system is engaged, it is a raw material and is an input for that finished product. Again, we do not see the relevance of this decision to the facts of the present case. It is nobody’s case before us that malted barley is not an input for the manufacture of Horlicks.\n<\/p>\n
14. In Paper Products Ltd., Bombay v. CCE, Bombay, 1984 (18) ELT 507 (Tribunal), the Tribunal held that the procedure prescribed in the Appendix to Notification No. 201\/79 dated 4.6.70 is substantially the same as set out in Rule 56A of the Central Excise Rules. Though the notification talks of exemption from so much of the duty of excise leviable thereon as is equivalent to the duty of excise already paid on the inputs, it is clear from the prescribed procedure that there is no requirement of exact co-relation of the inputs to the outputs, unlike set-off notifications where such co-relation is usually envisaged. The procedure permits the manufacturer to take credit of the duty that has already been suffered by the inputs and utilise such credits towards payment of duty on excisable goods for the manufacture of which the inputs were declared by the manufacturer to be brought into the factory.\n<\/p>\n
What the above decision implies is that there is no strict co-relation between the input and output envisaged in notification No. 201\/79 unlike set-off notifications. It would not follow from the above decision, nor is it an authority for the proposition, that the entire duty suffered by the input brought into the factory and utilised in the manufacture of the finished product is available for payment of duty on the finished product even though only a portion of the finished product is cleared on payment of duty from the factory. A strict co-relation would imply that a particular lot of input should be identified with a particular lot of output. Such co-relation is not envisaged. That is what the above decision purports to say.\n<\/p>\n
15.   The next decision is that of the Madras High Court in EID Parry (India)   Limited,   Madras   v.   Government   of   India   and   Ors.     1979-Cen Cus-370-D. The contention of  the Revenue in  that case was that  there   must  be a co-relation between the actual  quantity of the input   and  the   ultimate  product.   That,  according  to  the  Department,  was the   real   purport   and   intent  of   Rule   56A  (3)  (vi).   The  High  Court  took the   view   that   there  was  no  obligation  on   the  part-  of   the   manufacturer to  co-relate   the  input   rock  phosphate  with  the  ultimate  finished product (Fertilizers),1, so long as there was complete utilisation. In the case before the  Madras  High Court,  the entire output was being cleared on payment of  duty.  The   situation  which we are confronted with in the present case, namely, a part of the finished product was only being cleared on payment of duty, the remaining part being removed under Rule 56B without payment of  duty  from  the   factory  to  the  packing  stations  for  being  packed  into unit containers, was not there in the case before the High Court. Therefore, this decision against is no authority for Sri Engineer’s proposition.\n<\/p>\n
16.   Yet   another   decision   is   of   that   the   Tribunal   in   Vikrant   Tyres Ltd. v. CCE, Bangalore – 1985 (21) ELT-620. In that case, the raw materials   were   used   for   manufacturing   dutiable   tyres   as  well   as   exempted tyres. The appellant’s contention was that, at the time of taking the inputs into the factory and taking credit of the duty paid thereon, the appellant could not possibly say which of the raw materials would be used for manufacturing dutiable tyres and which exempted tyres. No fault could be found with the appellants for taking credit of the entire duty on the inputs. Once credit had been taken, there was no bar to its being utilised on any of the dutiable outputs which fell within the definition of “the said goods” in notification No. 201\/79. The contention of the revenue, on the other hand, was that credit of duty could not be taken or utilised in respect of inputs, used in the manufacture of exempted goods. The exemption in respect of any goods was relatable to the input used in the manufacture of those very goods. The Bench considered the basic question whether proforma credit of duty on inputs used in the manufacture of goods which were exempted from duty could be utilised for payment of duty on goods which were not exempted from duty. The Bench came to the conclusion that inputs used in the manufacture of exempted goods would have to be ignored for the purpose of operating the exemption notification. In other words, the duty paid on such inputs should not be taken into account at all for the purpose of granting exemption in terms of the notification. The Bench also took the view that the procedure prescribed in the Appendix to the Notification would necessarily have to be consistent with the substantive part of the notification and could not be read in such a way as to conflict with the main part.\n<\/p>\n
It is true that, in the present case, there is no question of part of the finished products, being exempted from duty, as was the case in the Vikrant Tyre case. The finished goods which were removed from the Rajahmundry factory to the packing stations without payment of duty in terms of Rule No. 56B would ultimately have suffered duty when they were cleared from the packing stations after being put into unit containers. The analogy may, therefore, not be on all fours. But the principle set out in Vikrant Tyre case would apply. The principle is that the duty suffered by the input used in the manufacture of finished products which are dutiable and cleared on payment of duty would alone be available for being utilised for payment of duty on the finished products.\n<\/p>\n
17.   Two   other   decisions   were   cited   –   Order No.   759\/84-C     dated 15.10.84 in Appeal No. ED (SB) (T) A.No. W\/81-C. Madras Rubber Factory v.   CCE,   Madras   and  Order   No.   138\/85   dated   1.2.85   in   Appeal   No. 1143\/81-C   of   the   same   appellant.   In  the   first  of   the  two  orders  (it  is not necessary  to discuss the second order which simply followed the first order),   the  question was  somewhat  more complicated  than’ in the present case.  There   was   a   question   of   transfer  of   credit   from  one  factory  to another. More importantly, the inputs in respect of the appellants’ factory at  Madras  felt   under  Item  No.   16A GET and not 68 GET.  In the  latter event   alone,   notification   No.   201\/79   would   come   into   play.   The   facts and   circumstances   being   different,   these   two   decisions   are   of   no   help in resolving the dispute before us.\n<\/p>\n
18.   Thus,   on   a   consideration   of   all   the   decisions   placed   before  us and   on   a   reading   of   notification   No.   201\/79,   we   are  of   the  view  that the credit of the duty suffered by the input, namely, malted barely, could be utilised by the Rajahmundry factory of the appellant .only to the extent of the duty suffered by the input used in the manufacture of the finished product  cleared  from  the  factory  on  payment of  duty.  Duty suffered by the  input  used  in  the  manufacture  of finished product  which was  moved from  the  Rajahmundry factory to the packing  stations located elsewhere, in terms of Rule No. 56B, without payment of duty, could not be utilised towards   payment   of   duty   on   the   finished   product   cleared   on payment of duty from the Rajahmundry factory.\n<\/p>\n
19.   As   stated   earlier,   the   Counsel   for   the   appellants   had  given  up the contention that credit of input duty earned at the Rajahmundry factory could   be   utilised   towards   payment   of   duty   on   Horlicks   (removed   under Rule  56B  from  the said factory to the packing  station  located elsewhere, such removals being without payment of duty) packed at the packing stations and  cleared  therefrom  on  payment  of  duty. In view of  this,  we  are not called upon, nor do we, record any finding on this contention.\n<\/p>\n
20.   In the above view of the matter, the appeal fails and is rejected.<\/p>\n","protected":false},"excerpt":{"rendered":"
Customs, Excise and Gold Tribunal – Delhi H.M.M. Limited vs Collector Of Central Excise on 13 June, 1986 Equivalent citations: 1986 (9) ECC 119, 1986 (8) ECR 254 Tri Delhi, 1987 (29) ELT 608 Tri Del ORDER G. Sankaran, Vice-President 1 This is an appeal directed against order No. 196\/84(G) dated 1.12.84 passed by the […]<\/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-78931","post","type-post","status-publish","format-standard","hentry","category-customs-excise-and-gold-tribunal-delhi","category-tribunal"],"yoast_head":"\nH.M.M. Limited vs Collector Of Central Excise on 13 June, 1986 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/h-m-m-limited-vs-collector-of-central-excise-on-13-june-1986\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"H.M.M. 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