{"id":98535,"date":"2001-10-09T00:00:00","date_gmt":"2001-10-08T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/collector-of-central-excise-vs-modi-rubber-ltd-on-9-october-2001"},"modified":"2015-03-13T22:07:15","modified_gmt":"2015-03-13T16:37:15","slug":"collector-of-central-excise-vs-modi-rubber-ltd-on-9-october-2001","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/collector-of-central-excise-vs-modi-rubber-ltd-on-9-october-2001","title":{"rendered":"Collector Of Central Excise, … vs Modi Rubber Ltd on 9 October, 2001"},"content":{"rendered":"
Supreme Court of India<\/div>\n
Collector Of Central Excise, … vs Modi Rubber Ltd on 9 October, 2001<\/div>\n
Author: P Reddi<\/div>\n
Bench: B.N. Kirpal, N. Santosh Hegde, P. Venkatarama Reddi<\/div>\n
           CASE NO.:\nAppeal (civil) 4090  of  1995\n\n\n\nPETITIONER:\nCOLLECTOR OF CENTRAL EXCISE, MEERUT\n\n\tVs.\n\nRESPONDENT:\nMODI RUBBER LTD.\n\nDATE OF JUDGMENT:\t09\/10\/2001\n\nBENCH:\nB.N. Kirpal, N. Santosh Hegde & P. Venkatarama Reddi\n\n\n\n\nJUDGMENT:\n<\/pre>\n
P.VENKATARAMA REDDI, J.\n<\/p>\n
In this appeal filed under Section 35 L (b) of the Central Excise and
\nSalt Act by the Revenue, the order of  CEGAT dated 21.2.1994  in its final
\norder No. 73\/94-C is under challenge.  By that order, the Tribunal rejected
\nthe Departments appeal following inter alia its earlier order in Vikrant
\nTyres Ltd. Vs. CCE Bangalore (1988 (38) ELT 301),  the appeal against
\nwhich filed by the Revenue was dismissed by us on 13.9.2001 on the ground
\nthat it became infructous in the light of subsequent event.\n<\/p>\n
\tLet us now take stock of the material facts giving rise to this appeal.
\nThe respondent herein is manufacturer of tyres, tubes and flaps.     The
\nrespondent was availing the proforma credit of duty on inputs viz. Synthetic
\nrubber, carbon black and rubber processing chemicals.  The proforma credit
\non those inputs to the tune of Rs.62,53,023\/- for the period 1.3.1984 to
\n14.3.1986 and Rs.5,64,236\/-  for the period November 1984 to February
\n1986  utilised in respect of tyres, tubes and flaps cleared at nil rate of duty
\nwas reversed\/debited  under protest, presumably at the instance of Excise
\nAuthorities.  Later, the respondent claimed refund thereof.  The case of the
\nrespondent was that the Notification No.95\/79 (as amended from time to
\ntime) nowhere prescribed that the proforma credit of duty paid on the inputs
\nwas available only in relation to duty-paid outputs.  The respondent
\ncontended that the relevant Notification did not envisage any link between
\ninputs and outputs.  By a reasoned order dated 11.12.1989, the Assistant
\nCollector of Central Excise, Meerut, rejected the assessees claim for refund.
\nHe held that the assessee was not entitled to avail of the benefit of proforma
\ncredit on the inputs used in the manufacture of final products i.e. tyres, tubes
\nand flaps which were cleared at nil rate of duty.  The Assistant Collector
\nconcluded that the proforma credit was correctly debited\/reversed by the
\nassessee and, therefore, the question of refund did not arise.\t In this context,
\nthe following  crucial finding\tin the order of the Assistant Collector
\ndeserves to be noted for the proper appreciation of the core issue involved:-\n<\/p>\n
In the present case, on examination of record, it is
\nnoticed that during the relevant period (for which refund
\nhas been preferred), the final product, namely, tyres,
\ntubes and flaps were cleared by the party at nil rate of
\nduty as the same were cleared as original equipment or
\nADV.\n<\/p>\n
The appeal filed by the assessee against the said order was allowed
\nby the Collector (Appeals) based on the Tribunals decision in Vikrant case
\n(supra).  Aggrieved thereby, the department filed an appeal before CEGAT.
\nThe CEGAT, by the impugned order, rejected the appeal, after quoting in
\nextenso its earlier order in Vikrant Tyres case.  In that case, the Tribunal
\nwhile construing the Notification No 95\/79  held that the Notification did not
\nhave any condition that\t there should be  nexus between the inputs and
\noutputs.  According to the Tribunal, the only question that can arise while
\nexamining the question of eligibility to this Notification is whether the
\ninputs described in column (3) have been used in the outputs described in
\ncolumn (5).  The Tribunal further observed:  the learned JDRs  argument
\nthat goods mentioned in column (5) (final products) are only those  which
\npay duty  is not supported by the wording of the Notification.\tNo condition
\nregarding payment of duty is contained anywhere in the Notification.  The
\ncorrectness of this view taken by the CEGAT is being assailed in this appeal.\n<\/p>\n
\tIn order to rationalise the overall impact of the duties of excise on the
\ncost of the final manufactured product, the Central government framed
\ncertain rules such as Rule 56A and issued certain Notifications in exercise of
\nthe powers conferred on it under sub-rule (1) of Rule 8 of the Central Excise
\nRules.\tFor instance Rule 56A which is a pre-cursor to the MODVAT
\nscheme now in vogue provided for allowance of credit of duty already paid
\non the materials or component parts used in the manufacture of finished
\nexcisable goods subject to certain conditions.\tThe Notification with which
\nwe are concerned in the present case is yet another   instance of Central
\nGovernments endeavour to reduce the duty otherwise payable   on the
\nfinished products.  That Notification is No. 95\/83 dated 1.3.1983.  It
\nprovides for input duty relief to specified goods.  The Notification is
\nextracted hereunder:-\n<\/p>\n
In exercise of the powers conferred by sub-rule
\n(1) of rule 8 of the Central Excise Rules, 1944, and in
\nsupersession of the notification of the Government of
\nIndia in the Ministry of Finance (Department of
\nRevenue) No. 95\/79-Central Excises, dated the 1st March,
\n1979, the Central Government hereby exempts excisable
\ngoods of the description specified in column (5) of the
\nTable hereto annexed (such goods being hereinafter
\nreferred to as final products) and falling under such
\nItem No. of the First Schedule to the Central Excises and
\nSalt Act, 1944 (1 of 1944), as is specified in the
\ncorresponding entry in column (4) of the said Table from
\nso much of the duty of excise leviable thereon under the
\nsaid Act, as is equivalent to the duty of excise leviable
\nunder the said Act, or the additional duty leviable under
\nthe Customs Tariff Act, 1975 (51 of 1975), as the case
\nmay be, already paid on the goods of the description
\nspecified in the corresponding entry in column (3) of the
\nsaid Table (such goods being hereinafter referred to as
\ninputs) and falling under such Item No. of the said First
\nSchedule as is specified in the corresponding entry in
\ncolumn (2) of the said Table:\n<\/p>\n
Provided that<\/p>\n
(i) the inputs specified in column (3) of the said
\nTable against a particular serial number in
\ncolumn (1) thereof are used in the
\nmanufacture of the final products specified
\nin the corresponding entry in column (5) of
\nthe said Table against the said serial
\nnumber;\n<\/p>\n
(ii) in relation to the exemption under this
\nnotification, the procedure set out in rule
\n56A of the aforesaid rules is followed.\n<\/p>\n
The columns in the Table and relevant items therein are given below :\n<\/p>\n
____________________________________________________________
\nS.No.\t Item No. of\t    Description of\t     Item No. of\t   Description
\n       the said First\tinputs\t\t\t    said First\t   of final products
\n\t Schedule\t\t\t\t      Schedule
\n(1)\t (2)\t\t       (3)\t\t       (4)\t     (5)<\/p>\n
19\t16AA\t\tSynthetic rubber       16\t  Tyres, tubes & flaps
\n20\t64\t\tCarbon black\t       16\t  Tyres, tubes & flaps
\n21\t65\t\tRubber processing      16\t  Tyres, tubes & flaps
\n\t\t\t       chemicals<\/p>\n
Be it noted that this Notification dated 1.3.1983  was issued\tin supersession
\nof the Notification No.95\/79 dated 1.3.1979.  Reference has been wrongly
\nmade to this Notification of 1st March, 1979 both by the Assistant Collector
\nand the Tribunal, as if that is the Notification applicable for the relevant
\nperiod.\t However, it must be mentioned that the Notification No. 95\/79 is
\nsubstantially similar to the Notification dated 1.3.1983  except with  this
\ndifference, i.e., the following proviso was omitted :-\n<\/p>\n
(ii)  where the duty of excise leviable on any final
\nproduct is  less  than the amount of duty of excise
\n(including special duty of excise aforesaid) of the
\namount of additional duty aforesaid, as the case
\nmay be, paid on the inputs used in the manufacture
\nof such final product, the extent of exemption shall
\nbe restricted to the duty of excise leviable on such
\nfinal product.\n<\/p>\n
One more point of detail to be referred to at this juncture is that the inputs,
\nnamely, synthetic rubber, carbon black and rubber processing chemicals did
\nnot find place in column (3) of the table appended to the Notification No
\n95\/79, but they were subsequently added by means of Notification No. 58\/82
\ndated 28.2.1982.  This Notification No. 95\/79 (as amended from time to
\ntime) was ultimately superseded by the Notification No. 95\/83 dated
\n1.3.1983.  It is that Notification which is relevant to the period for which the
\nclaim has been preferred by the assessee.   It is common ground that the
\nanswer to the controversy arising in the present case depends on the
\ninterpretation of that notification.\n<\/p>\n
\tThe interpretation of the Notification No. 95\/83 does not present any
\ndifficulty.  The Notification provides for exemption of excisable goods
\ndescribed in column (5) of the Table (extracted supra), referred to as final
\nproducts.  The extent and amplitude of exemption is set out in clear terms.
\nThe exemption is to the extent of duty of excise  already paid on the goods
\nof the description specified in column (3) of the Table, that is to say, on
\ninputs.\t Proviso I in explicit terms enjoins that the inputs specified in column
\n(3) of the Table should have been used in the manufacture of final products
\nspecified in corresponding entry in column (5). What is exempted is so
\nmuch of the  duty of excise leviable thereon.  The expression thereon is
\nreferable to excisable goods described in column (5)  known as final
\nproducts.   The extent to which it is exempted is limited to the duty of
\nexcise leviable and already paid on the goods of the description specified in
\ncolumn (3)  known as inputs.   In other words, the duty paid on the inputs
\nis adjusted against the duty payable on the final products manufactured out
\nof the said inputs and the balance only is liable to be paid on the finished
\nproducts.   Thus, the excise duty payable on the final products or outputs has
\ninextricable nexus with the duty paid on inputs for which the credit of duty
\nis allowed in accordance with the procedure laid down in Rule 56A.  The
\nexemption Notification pre-supposes that the duty is otherwise payable on
\nthe finished products specified therein.  There is no question of applying this
\nNotification to the finished products (in this case tyres, tubes and flaps) if
\nthey are not subjected to any duty.\n<\/p>\n
\tIt is contended that the omission of clause (ii) of the proviso
\ncontained in the earlier Notification No. 95\/79 is significant.\t It is pointed
\nout that the extent of exemption was in restricted terms  as it was made clear
\nthat it could not exceed the amount of duty paid on the inputs.\t  That clause
\nhaving been removed in 1983, the exemption should be construed widely
\nand without regard to the question whether the inputs go into the
\nmanufacture of dutiable or non-dutiable finished products.  We find it
\ndifficult to accept this contention.  The omission of provision similar to
\nclause (ii) of the proviso to Notification No. 95\/79 does not, in our view,
\nadvance the case of the respondent.  Even the words employed in the
\nopening part of the Notification No. 95\/83 are sufficient enough to take care
\nof a situation which was provided for expressly in the proviso to Notification
\nNo. 95\/79.  We, therefore, see no force in this contention.\n<\/p>\n
\tHaving thus understood the true scope and purport of the Notification,
\nwe shall proceed to consider whether the claim of the respondent  assessee
\nis sustainable.\t We have already adverted to the finding of the Assistant
\nCollector that during the relevant period for which refund had been
\npreferred, the final products were cleared by the assessee at nil rate of duty.
\nThus, during the crucial period, none of the inputs for which proforma credit
\nhad been taken by the assessee went into the production of dutiable goods
\ni.e., tyres and tubes.\tThis finding remains unrebutted.  If so, in our view, the
\nrespondent cannot take advantage of the Notification No. 95\/83 and claim to
\navail of  the credit of input duty during that period.\tOnce the entire inputs
\n(for which the credit has been claimed) are utilised in non-dutiable tyres, the
\ncredit lapses to that extent.\tThere is no difficulty in pin-pointing\tthat all the
\ninputs were utilised only in the manufacture of non-dutiable finished
\nproducts because no dutiable tyres and tubes were cleared at all during the
\nrelevant period.  If so, the respondent cannot derive any benefit under the
\nNotification No.95\/83.\tThe Notification issued under Rule 8 (1) deals with
\nduty exemption on final products.  The exemption is worked out with
\nreference to the duty paid on the inputs by adjusting the input duty against
\nthe duty payable on final products.  Such adjustment is not possible when no
\nduty at all is payable on the finished product.\t Input duty relief and the duty
\npayable on finished goods are thus inter-linked.  There is nothing in the
\nnotification which enables input duty credit to be maintained and availed of
\nmerely because the inputs are used in the manufacture of specified finished
\nproducts.  The further premise is that the finished products are such that are
\nsubjected to duty.  Any other  interpretation would confer an unintended
\nbenefit on the assessee.  The idea underlying the Notification No. 95\/83, as
\nalready noted, is to check or minimise the cascading effect of duties which
\nare otherwise payable at various stages.  It could not be the underlying
\nintention of notification  to grant the relief of duty on inputs as well as the
\ncorresponding outputs.\tExemption notification cannot be unduly stretched
\nto produce unintended results in derogation of the plain language employed
\ntherein.\n<\/p>\n
\tThe arguments of learned senior counsel for the respondent have
\nthroughout proceeded on the basis that there need not be  correlation
\nbetween the inputs and the finished products for claiming credit of duty paid
\non the inputs.\tStrong reliance is placed to support this argument on the
\ndecision of this Court in H.M.M. Ltd.  Vs.  Collector of Central Excise, New
\nDelhi  (1996, 87 E.L.T., 593).\tWhile construing a somewhat similar
\nnotification No. 201\/79,  it was observed therein :-\n<\/p>\n
The rules do not require any exact correlation between
\nthe inputs and the finished products for claiming credit
\nfor the duty ;paid on the inputs.  It is not a condition-
\nprecedent for claiming set-off that the manufacturer must
\nprove that<\/p>\n
(a) the credit was taken in respect of inputs; and that<\/p>\n
(b) these very inputs were utilised in the  manufacture
\n\t\t\t\tof the goods on which duty is payable.\n<\/p>\n
Rule 2 merely provides that the manufacturer may
\ntake credit of the duty already paid on the inputs
\nand utilise such credit for payment of duty of
\nexcise on the manufactured goods.  The exact
\ncorrelation of inputs with the manufacture of the
\ngoods is not contemplated by this rule.\n<\/p>\n
\t\t\t\t\t\t       (emphasis supplied)<\/p>\n
\tThis Court relied on Rules 9 and 10 appended to the notification to
\ninfer the absence of  correlation between the inputs and the finished goods.
\nIt was observed at paragraph 9 :-\n<\/p>\n
All these rules really go to show that there was no
\nrequirement of actual utilisation of the inputs in the
\nmanufacture of the goods for the purpose of claiming set-
\noff of duty paid on the inputs against the duty payable on
\nthe goods manufactured by the manufacturer.\n<\/p>\n
\t\t\t\t\t\t  (emphasis supplied)<\/p>\n
\tThe ratio of the decision will best be understood by noting the
\nillustration given therein indicating the scope of controversy :-\n<\/p>\n
The manufacturer (Respondent) purchases 100 tons of
\nbarley malt on which the duty paid is Rs.10,000\/-.  By
\nusing the said 100 tons of barley malt, the respondent
\nmanufactures one thousand tons of Horlicks.  Out of this
\none thousand tons, it clears 250 tons of Horlicks from the
\nRajahmundry factory on paying duty.  The remaining 750
\ntons is sent to the factory  situated at Bangalore without
\npaying duty under a bond.  The 750 tons is put in unit
\ncontainers and packages at the Bangalore factory and
\ncleared from there on payment of excise duty.  According
\nto the appellant, he is entitled to take credit for the entire
\nduty of Rs.10,000\/- (paid on 100 tons of barley malt)
\nfrom out of the duty payable on 250 tons of Horlicks
\ncleared from Rajahmundry factory, whereas according to
\nthe Revenue, since the quantity cleared at Rajahmundry
\non payment of duty is only 1\/4th of the\t total quanity
\nmanufactured using 100 tons of barley malt, the appellant
\nis entitled to take credit of only Rs.2,500\/- against the
\nduty payable at Rajahmundry.  Revenue also says that the
\nrespondent is not entitled to take credit of balance of
\nRs.7,500\/- (duty paid on 75 tons of barley malt) from out
\nof the duty paid on 750 tons at Bangalore.  The question
\nis who is right?\n<\/p>\n
\tIt is obvious  that in that case, duty was payable on the entirety of
\nfinished product, namely, Horlicks, whether cleared at Rajahmundry factory
\nor despatched to Bangalore factory under a bond.  The controversy arose as
\nto the point of time and the quantity in respect of which the input duty credit
\ncould be taken.\t In the instant case, as already noted, no duty was liable to be
\npaid on any part of the finished goods viz. tyres and tubes cleared during the
\nrelevant period.  The issue of correlation on one-to-one basis does not really
\narise for consideration here.  The question of correlation has some
\nimportance  where excise duty is payable on part of the goods and no duty is
\npayable on the remaining part.\tThe issue in the present case is quite
\ndifferent, the issue being whether the credit of duty on inputs could be
\navailed of notwithstanding the fact that the inputs were utilised only in the
\nmanufacture of duty-free finished products.  That issue has to be answered
\nagainst the respondent – assessee in the light of the foregoing discussion.
\nThe decision in H.M.M. Ltd. Case (supra) does not come to the aid of the
\nrespondent.  On the other hand, the underlined portions in the passages
\nextracted supra would indicate that the interpretation placed by the Court on
\nthe notification is no different.\n<\/p>\n
\tWe may add that it has never been the case of the respondent that
\nthere was reasonable likelihood of the credit being set-off against the
\ndutiable finished products in the near future.\tIn fact, contentions of the
\nparties have not focussed on the modalities\/procedure of claiming credit on
\ninputs in the given situation and the maintainability of refund applications.
\nWe need not therefore go into these procedural aspects.\n<\/p>\n
\tThe decision of the Delhi High Court in Good Year India Ltd.  Vs.
\nUnion of India\t(1990, 49  ELT 39) and that of the Bombay High Court in
\nJaysynth Dyechem Pvt. Ltd.  Vs. Union of India\t(1991, 51 ELT 246)
\nreferred to by the learned counsel are not of any help to the respondent.  The
\nHigh Court of Delhi after referring to the Notification No. 201\/79 (which
\nwas interpreted by this Court in H.M.M. case, supra) laid down the
\nproposition as follows:-\n<\/p>\n
Under the present notification, a manufacturer is
\nrequired to take proforma credit of the duty, paid on
\ninputs, as soon as, the inputs are brought into the factory.
\nThis credit is then utilised and the manufactured goods
\nare cleared and is not linked to any particular item of the
\nmanufactured product.  The language of the new
\nnotification, does not require the inputs to be correlated
\nwith end-product.\n<\/p>\n
It was then observed :-\n<\/p>\n
In fact, the scheme provides that the credit can be
\nutilised for payment of duty, against any excisable
\nproducts, that are brought from the factory.  No debit can
\nbe claimed after the credit has been taken on goods,
\nbrought\t into the factory.  Once raw materials enter the
\nfactory of petitioner company, credit is to be taken in
\naccordance with the procedure, prescribed in the Rules,
\nwithout any correlation to the end product.  The credit
\ncan be utilised by petitioner, for the payment of duty on
\nany goods, for which credit is taken.  These goods need
\nnot be exempted goods, but will be those goods, on
\nwhich duty is payable under the Act.\n<\/p>\n
\tFar from coming to the aid of the respondent the view expressed by
\nthe Delhi High Court  makes it clear that the question of utilising the credit
\non inputs would arise only where the duty is payable on finished product.\n<\/p>\n
\tIn  the case of Jaysynth Dyechem Pvt. Ltd.  Vs.\t Union of India
\n(1991, 51 ELT 246), the Bombay High Court was construing an exemption
\nnotification in which a proviso similar to the one which is contained in
\nNotification No. 95\/83 was construed by the High Court.\t  The High Court
\nheld that the said proviso deals with the procedure to be followed in availing
\nof set off  of countervailing customs duty paid on imported intermediaries,
\nbut does not import the substantive provision of Rule 56A so as to defeat the
\nexemption.  It is not necessary, in the present case, to go into the question of
\ninterplay of Notification No. 95\/83 and Rule 56A.  The view taken by us
\ndoes not rest on any substantive provision of Rule 56A.\n<\/p>\n
\tFor the reasons aforesaid, we are of the view that the impugned order
\nof the CEGAT  is erroneous in law and liable to be quashed.\n<\/p>\n
\tHowever, before parting with the case, it is necessary for us to advert
\nto the preliminary objection raised on behalf of the respondent.  It is
\ncontended that in the instant case the appeal under Section 35-L(b)  does not
\nlie for the reason that no question arises in the present appeal which has a
\nrelation to the rate of duty of excise or to the value of goods for purposes of
\nassessment within the meaning of clause (b) of Section 35-L.  Reference is
\nmade to the decision in\t Navin Chemicals Mfg. & Trading Co. Ltd.  Vs.
\nCollector of Customs  (1993, 68 ELT 3).\t  In that case,\t this Court pointed
\nout that the question to be decided must have direct and proximate
\nrelationship  to the rate of  duty and to the value of goods for the purposes of
\nassessment.  The contention is that no such question is involved in the
\npresent case.\tHowever, the following observations  in the same case
\ndeserve notice :\n<\/p>\n
A dispute as to the classification of goods and as to
\nwhether or not they are covered by an exemption
\nnotification relates directly and proximately to the rate of
\nduty applicable thereto for purposes of assessment.\n<\/p>\n
\tBased on the above dicta,  it is possible to contend, as has been
\ncontended before us, that the question as to rate of duty is involved in the
\npresent case.  However, we need not express any opinion on this aspect.
\nNotwithstanding the initial omission on the part of the appellant in invoking
\nthe jurisdiction of this Court under Article 136, at least by way of abundant
\ncaution,  the learned Additional Solicitor-General appearing for Union of
\nIndia did make an oral prayer to treat this appeal as one filed under Article
\n136 as well.  A formal application in this behalf has been filed after the
\nconclusion of the arguments in the case. The respondent has filed a reply
\nopposing the application.  We are of the view that in the interests of justice
\nand in order to put an end to this long-standing litigation, we deem it just
\nand proper to allow the application.  It is not advisable at this stage after a
\nlapse of six years to reject the appeal as not maintainable and relegate the
\nappellant to the course of seeking remedy by way of  reference to the High
\nCourt, assuming that the appeal under Section 35-L(b) does not lie.
\nIncidentally, it may be pointed out that in  Commissioner of Central Excise
\n& Customs  vs.\tVenus Castings (P) Ltd.<\/a> (2000 4 SCC 206), this Court did
\nallow such application at the time of hearing of appeal.  We do not think
\nthat there is anything in the decisions of this Court in  Steel Authority of
\nIndia Ltd.   Vs.  Collector of Central Excise [1996 (82) ELT 172] and
\nFerro Alloys Ltd.  Corporation Vs.  Collector of Central Excise [1996
\n(82) ELT 173] which stands in the way of the application, though belated it
\nis, being allowed.  In the first case, the appeal was rejected at the admission
\nstage on the basis of concession and the appeal in the second case was also
\nrejected at the threshold itself.  Apparently, no request was ever made to
\npermit the appellant to invoke the jurisdiction of this Court under Article
\n136 of the Constitution.\n<\/p>\n
\tThe appeal is allowed and the impugned order of CEGAT is set aside.
\nParties to bear their own costs.\n<\/p>\n
\t\t\t\t\t\t\t..J
\n\t\t\t\t\t\t\t(B.N. Kirpal)<\/p>\n
\t\t\t\t\t\t\t..J
\n\t\t\t\t\t\t\t(N.Santosh Hegde)<\/p>\n
\t\t\t\t\t\t\t..J
\n\t\t\t\t\t\t\t(P.Venkatarama Reddi)
\nOctober\t 09, 2001.<\/p>\n","protected":false},"excerpt":{"rendered":"
Supreme Court of India Collector Of Central Excise, … vs Modi Rubber Ltd on 9 October, 2001 Author: P Reddi Bench: B.N. Kirpal, N. Santosh Hegde, P. Venkatarama Reddi CASE NO.: Appeal (civil) 4090 of 1995 PETITIONER: COLLECTOR OF CENTRAL EXCISE, MEERUT Vs. RESPONDENT: MODI RUBBER LTD. DATE OF JUDGMENT: 09\/10\/2001 BENCH: B.N. Kirpal, N. […]<\/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":[30],"tags":[],"class_list":["post-98535","post","type-post","status-publish","format-standard","hentry","category-supreme-court-of-india"],"yoast_head":"\nCollector Of Central Excise, ... vs Modi Rubber Ltd on 9 October, 2001 - 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\/collector-of-central-excise-vs-modi-rubber-ltd-on-9-october-2001\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Collector Of Central Excise, ... vs Modi Rubber Ltd on 9 October, 2001 - 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