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314ta 31•147T .w5zii Order-In-Appeal No..AHM-EXCUS-001-APP-065-13-14
ft-4T Date : 03.01.2014 4 Date of Issue I c( -oft I
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Passed by Shri. Anil Kumar, Commissioner (Appeal -V)
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Remission/01/Addl.Commr/2013 ff-41-T: 26.08.2013 34 3=117
Arising out of Order- in -Original No.Remission/01/Addl.Commr12013 Dated : 26.08.2013
Issued by Addl., Central Excise, Div.-II Ahmedabad-I..
3T-11-6M--dt 0, 1 Lim Name & Address of the Appellant / Respondent
Prasad GWK Cooltech Pvt. Ltd. Ahmedabad
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-q--dT 3i a9-9 31-f0mrt (4-)1 3icit& TIT iTtafur 31-1k-4-- 'CR7 Th7 fl4oc1I t I Any person a aggrieved by this Order-In-Appeal may file an appeal or revision application, as
the one may be against such order, to the appropriate authority in the following way :
FRU *NovI Th-T ifftra-Tur 3Te4-4-9. Revision application to Government of India :
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(i) A revision application lies to the Under Secretary, to the Govt. of India, Revision Application Unit
Ministry of Finance, Department of Revenue, 4 th Floor, Jeevan Deep Building, Parliament Street, New
Delhi -
110 001 under Section 35EE of the CEA 1944 in respect of the following case, governed by first
proviso to sub-section (1) of Section-35 ibid :
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(ii) In case of any loss of goods where the loss occur in transit from a factory to a warehouse or to another factory or from one warehouse to another during the course of processing of the goods in a
warehouse or in storage whether in a factory or in a warehouse.
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In case of rebate of duty of excise on goods exported to any country or territory outside India of on excisable material used in the manufacture of the goods which are exported to any country or territory outside India.
4 T Tr-d-rff q,q 41-Rff (ffcrrR trr Taff - c r) f4zriff ftzrr Trzrr 411e1 tr
In case of goods exported outside India export to Nepal or Bhutan, without payment of duty.
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(d) Credit of any duty allowed to be utilized towards payment of excise duty on final products under the provisions of this Act or the Rules made there under and such order is passed by the Commissioner (Appeals) on or after, the date appointed under Sec.109 of the Finance (No.2) Act, 1998.
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The above application shall be made in duplicate in Form No. EA-8 as specified under Rule, 9 of Central Excise (Appeals) Rules, 2001 within 3 months from the date on which the order sought to be appealed against is communicated and shall be accompanied by two copies each of the 010 and Order-In-Appeal. It should also be accompanied by a copy of TR-6 Challan evidencing payment of prescribed fee as prescribed under Section 35-EE of CEA, 1944, under Major Head of Account.
(2) fro--- ff 31T-4--4-9 Ti12.1 vel c-1 , -I 7T1=1. Lc W:It TIT \.i.t-H c17 4-1 -1:14"' 200 / — thti 11-TEd1-9 v1N 3117 vel -1 419 ct) •Rk v414r 1 t 1000 / — 4 rite Trffrff
The revision application shall be accompanied by a fee of Rs.200/- where the amount involved is Rupees One Lac or less and Rs.1,000/- where the amount involved is more than Rupees One Lac.
At9T Th--41.4 \30414-1 31-0A-zE :fl-ZITI4TTETT Appeal to Custom, Excise, & Service Tax Appellate Tribunal.
(1) \--41-Ti 31ItiftTITI, 1944 Mei URI 35—t /
U n der Section 35B/ 35E of CEA, 1944 an appeal lies to :- () cogctrui vqict)-r3f -414-d ITFO -trir 3c1-114 -1 J 5 (T-4 3T41 r
That 14-tlf iftitTh-T Edict" 9. 3. 31-R. vq'
(a) the special bench of Custom, Excise & Service Tax Appellate Tribunal of West Block No.2, R.K. Puram, New Delhi-1 in all matters relating to classification valuation and.
3
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(b) To the west regional bench of Customs, Excise & Service Tax Appellate Tribunal (CESTAT) at 0-20, New Metal Hospital Compound, Meghani Nagar, Ahmedabad : 380
016. in case of appeals other than as mentioned in para-2(i) (a) above.
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The appeal to the Appellate Tribunal shall be filed in quadruplicate in form EA-3 as prescribed under Rule 6 of Central Excise(Appeal) Rules, 2001 and shall be accompanied against (one which at least should be accompanied by a fee of Rs.1,000/-, Rs.5,000/- and Rs.10,000/- where amount of duty / penalty / demand / refund is upto 5 Lac, 5 Lac to 50 Lac and above 50 Lac respectively in the form of crossed bank draft in favour of Asstt. Registar of a branch of any nominate public sector bank of the place where the bench of any nominate public sector bank of the place where the bench of the Tribunal is situated. Application made for grant of stay shall be accompanied by a fee of
Rs.500/-.
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f+-zrT \311.-11 .Fft. Mzi 6)e) V '1-i)f '12 1T .L1 r). T-14 f z12TTftelft 31 A-4
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In case of the order covers a number of order-in-Original, fee for each 0.1,0. should be paid in the aforesaid manner not withstanding the fact that the one appeal to the Appellant Tribunal or the one application to the Central Govt. As the case may be, is filled to avoid scriptoria work if excising Rs. 1 lacs fee of Rs.100/- for each.
(4) --t11-11c14 3Tf4f4Ili 1970 IRIT 7.471)-10.d. 4 31- ilt— 1 fgal-ftd. f 371-ffF 3.T1 311da9 zfr
11.a. 31 31 ZRTIR-P-40. ATf4T171 311 YT 7) 1;1.-0!IT TC L ch Aft x.6.50 17) TT RI 1 ci
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One copy of application or O.I.O. as the case may be, and the order of the adjournment authority shall a court fee stamp of Rs.6.50 paise as prescribed under scheduled-I item of the court fee Act, 1975 as amended.
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M \30-11.-f ci 41c11(M. 3141 1ZT . 11-41111.T7.7 (c1) 1 .z11=1., 1982 f t.
Attention in invited to the rules covering these and other related matter contended in the Customs, Excise & Service Tax Appellate Tribunal (Procedure) Rules, 1982.
( 3 )
(5)
4 F.No. V.2(84)42/Ahd-I/2013
ORDER -IN -APPEAL
M/s Prasad GWK Cooltech Pvt. Ltd., Plot no. 4, A-4, Phase-I, GIDC
Estate, Vatva, Ahmedabad (hereinafter referred to as the appellant) has filed an
appeal against 0.1.0 No. Remission/01/Addl. Commr./2013, dated 26.08.2013,
(hereinafter referred to as "the impugned order"), passed by the Additional
Commissioner, Central Excise, Ahmedabad -I.
2. The brief facts of the case is that the appellant is engaged in
manufacture of goods falling under Chapter 84 of Central Excise Tariff Act, 1985 and
is registered with the Central Excise department. They have cleared "Air Cool Compact Water Chiller" having assessable value Rs. 14,20,940/- and Central Excise
duty amounting to Rs. 1,46,357/- under ARE-1 No. 26/2010-11 dated 13.07.2010 for
export under bond, without payment of Central excise duty, vide shipping bill no.
8652102 dated 13.07.2010. LEO was issued by customs department on 15.07.2010.
The export cargo, along with the container No. MEDU1177837 was loaded on vessel MSC Chitra, which met with an accident in the sea, away from port. The goods were
lost and the same could not be salved and was considered a total loss.
3. During the course of audit of the unit, it was noticed that the appellant had claimed insurance of the goods destroyed in the sea and received the insurance amount against Export Invoice No. 18, dated 13.07.2010. As the goods, so destroyed, were liable to payment of duty alongwith interest from the date of clearance, under provision of Notification no. 42/2001-C.E.(N.T.) dated 26.06.200, the appellant on being pointed out by Audit has paid the Central Excise duty of Rs.1,46,357/- by
debiting the same to their Cenvat account and also paid the interest of Rs.38,145/-
vide challan dated 06.03.2012 in PLA. The appellant vide letter dated 06.05.2012, applied for the remission of excise duty for the said goods destroyed in transit, under the provision of Rule 21 of the Central Excise duty amounting to Rs. 1,46,357/-.
4. Remission of duty: RULE 21 OF CENTRAL EXCISE RULES, 2002 states as under:
"Where it is shown to the satisfaction of the Commissioner that goods have been lost or destroyed by natural causes or by unavoidable accident or are claimed by the manufacturer as unfit for consumption or for marketing, at any time before removal, he may remit the duty payable on such goods, subject to such conditions as may be imposed by him by order in writing "
5. The appellant's claim for remission of Central Excise duty amounting to Rs.1,46,357/-, was rejected by the adjudicating authority vide the impugned order, on the grounds that the basis criteria of remission being allowed only on goods destroyed at any time before removal, was not fulfilled.
5 F.No. V.2(84)42/Ahd -I/2013
6. Being aggrieved with the impugned order, the appellant has filed this
appeal on the following grounds.
GROUNDS OF APPEAL :
(i) In case of loss of goods, which was due to unavoidable circumstances,
remission of duty on goods lost should be allowed. The appellant cleared
goods for export under bond on 13.07.2010 under shipping bill no. 8652102
dated 13.07.2010. For these goods LEO was issued on 15.07.2010. The goods
were loaded on vessel MSC Chitra on 07.08.2010. The vessel met with an
accident in the sea and the goods sunk in sea water, which could not be
salved. This proves that export was completed.
(ii)They have relied on the judgement in the case of CCE Coimbatore V/s Shree
Narasimha Textile Ltd.(CESTAT Chennai) (2008-TIOL-2126-CESTAT-MAD).
(iii)They have correctly availed exemption under notification no. 42/2001-
C.E.(N.T.). At the time of exporting the goods the appellant has complied with
all the conditions as prescribed under notification no. 42/2001- CE (NT).
Therefore the exemption under the said notification cannot be denied to the
appellant.
(iv)The export of said goods could not be executed due to unavoidable
circumstances.The said goods were destroyed and not been subjected to home
consumption. Therefore the cancellation of application cannot be done by the
authority and exemption under the said notification cannot be denied to the
appellant. The appellant has wrongly paid the amount claimed as exempt which
could not be exported due to unavoidable circumstances. They have relied on
the judgment in the case of M/s. Kuntal Granites Ltd. Vs. The Commissioner of
Central Excise, Bangalore reported at 2007-TIOL-930-CESTAT -(BAN G)
DISCUSSION AND FINDINGS
7.Personal hearing in the matter was held on 17.12.2013, wherein Shri
Bishan R. Shah, Chartered Accountant, appeared before me on behalf of the
appellant and reiterated the grounds stated in their written submission. He also
stated that the appellant has not claimed Excise duty from the Insurance Company
and requested that their appeal be allowed.
8.The appellant, vide their letter dated 20.12.2013, has submitted the
6 F.No. V.2(84)42/Ahd-I/2013
following documents, as discussed during the course of Personal hearing.
(i) Copy of the Policy Schedule of the Marine Cargo Open Policy with the Insurers viz. Tata AIG General Insurance Company Ltd.
(ii) Copy of Receipt of the Insurance premium paid.
(iii) Copy of the letter of Insurance Claim.
(iv) Copy of the Discharge Voucher acknowledging the receipt of Rs. 1563034/- submitted to M/s. TATA-AIG General Insurance Co. Ltd.
(v) Copy of the Export Invoice no. EXP/019/2010-11, dated 10.7.2010, having a total value of USD 30,890/- (Rs. 14,20,940/-)
(vi) Certificate dated 20 th December, 2013, issued by TATA-AIG General Insurance Co. Ltd. certifying that an amount of Rs. 15,64034/- has been paid to the appellant, which is 110% of the Invoice value and that Excise duty is not reflected in the Invoice. It is also certified that the amount paid to M/s. Prasad GWK Cooltech Pvt. Ltd. is for Marine insurance claim for the goods lost in sea when the vessel MSC Chitra met with an accident.
9. The appellant, vide the above letter, has submitted that the incidental
10`)/0 received by them from the Insurance Company does not represent Excise duty
and that as per Marine Policy, every insurer has to pay 10 % of loss for incidental
expenses.
10. I have gone through the brief facts of the case, the impugned order, the
grounds of appeal filed by the appellant, the submissions made during the course of
Personal Hearing and the documents submitted by the appellant as detailed in the
above Para no.8. The main issue to be decided in this appeal is whether the claim for
Remission of duty filed under Rule 21 of the Central Excise Rules, 2002, is admissible to
the appellant, when the goods exported were lost in transit in sea and the appellant has
been compensated by the Insurance Company for the amount of Rs. 15,63,034/-.
11. On going through the impugned order, I find the goods viz. "Air Cooled
Compact Water Chiller", lost in sea, was totally worth Rs.15,67,297/-, having assessable
value of Rs.14,20,940/-, and involving Central Excise duty of Rs.1,46,357/-. On going
through the documents submitted by the appellant with respect to the Insurance amount
reimbursement to them by the Insurance Company viz. M/s. TATA AIG General
Insurance Company Ltd., I find that an , amount of Rs.15,63,034/- has been paid to the
appellant. This amount includes the amount of Rs.14,20,940/- which is the value of the
Export Invoice no. EXP/019/2010-11, dated 10.07.2010 and an additional 10 % which is
paid by the insurer as per the Marine Policy for incidental expenses, which is evident
from the certificate issued by the Insurance Company. It has also been certified that
Excise duty is not reflected in the said invoice. As such, it is evident that the appellant
has not been reimbursed the amount of Excise duty amounting to Rs.1,46,357/- by the
Insurance Company. Therefore, I do not agree with adjudicating authority, who vide
7 F.No. V.2(84)42/Ahd-I/2013
Para no. 13 of the impugned order, has stated that the appellant has been compensated
by the insurers for the value of the finished goods amounting to Rs.15,63,034/-, which is
inclusive of the amount of Excise duty.
12. Remission of duty: RULE 21 OF CENTRAL EXCISE RULES, 2002 states
as under:
"Where it is shown to the satisfaction of the Commissioner that goods have been lost or
destroyed by natural causes or by unavoidable accident or are claimed by the manufacturer as
unfit for consumption or for marketing, at any time before removal, he may remit the duty
payable on such goods, subject to such conditions as may be imposed by him by order in writing "
13. From the facts of the case, I find that the goods on which the Remission
of duty has been claimed, had been cleared from the factory and the said cargo met
with an accident in transit after LEO was issued on 15.07.2010 by the Customs
authorities.As such, the adjudicating authority has rejected the claim of remission of
duty on the grounds that the basic criteria for allowing remission of duty under Rule 21
of Central Excise Rules, 2002, i.e. it is allowed only if the goods are destroyed due to
natural or unavoidable accident and at any time before being removed, has not
been
fulfilled. Thus, in terms of the above mentioned provision of Rule 21 ibid, according to
the adjudicating authority, the appellant is not entitled to remission of duty.
14. Hon'ble Supreme Court in the case of M/s. Rajindra Dyeing and Printing
Mills Ltd., reported at 2005 (180) E.L.T. 433 (S.C.) has held :
"Drawback - Accident of ship within the territorial waters of India - Export cargo loaded on ship
which sailed from Bombay but met with an accident and sank within the territorial waters of India
destroying cargo loaded therein - HELD : Drawback not available as there was no export of the cargo.
Export goods - Destroyed in accident of ship within territorial waters of India - Drawback no available as
goods not exported - Rule 2(a) of the Customs & Central Excise Duty Drawback Rules, 1971."
15.The decision is relevant to this case, as here in this case also, the goods
were lost in transit and had not crossed the Territorial waters of India and in light of the
above judgement of the Hon'ble Supreme Court, it is construed that the goods lost in
sea were not exported. As such, the basic criteria for allowing Remission of duty under
Rule 21 of Central Excise Rules, 2002, that the goods are destroyed due to natural or
unavoidable accident and at any time before being removed, has been fulfilled and the
appellant is eligible for remission of duty.
16.Rule 3 of the Central Credit Rules, 2004 has been amended vide
Notification No. 33/2007-C.E. (N.T.), dated 7-9-2007 and Sub-rule 5C has been added.
Rule 3 (5C) of the Cenvat Credit Rules, 2004 states as under:
8 F.No. V.2(84)42/Ahd-I/2013
"Where on any goods manufactured or produced by an assessee, the payment of duty is ordered to
be remitted under rule 21 of the Central Excise Rules, 2002, the CENVAT credit taken on the inputs
used in the manufacture or production of said goods shall be reversed."
17. Hon'ble High Court of Gujarat, in the case of M/s. Intas Pharmaceuticals
Ltd, reported at 2013 (289) E.L.T. 256 (Guj.) has held:
"Cenvat credit - Claim of — Remission of duty on destruction of final product - Credit taken on
inputs used in manufacture of such final product - HELD : Prior to introduction of Rule 3(5C) of
Cenvat Credit Rules, 2004, there was no provision for reversal of credit lawfully taken, and it
could not be done either on equitable doctrine or double benefit accruing to assessee - However,
after introduction of Rule 3(5C) ibid, Legislature has made its intention clear, and reversal of
credit is required - If is a new right created in favour of Revenue, and in absence of any contrary
intention, it operates prospectively"
17.1. While passing the order, the Hon'ble High Court has also observed as
under:
16.If we go through the provisions of the Rules relating to Cenvat, we find that prior to
introduction of sub-rule (5C), there was no provision, which provided for reversal of the credit by the
excise authorities where it has been lawfully taken by a manufacturer. Therefore, the credit accrued at the
moment the raw material or the input was used in manufacturing of a final product which was neither
exempt from duty nor carried nil rate of duty. Such being the provision, as it stood in the Cenvat Credit
Rules prior to September 7, 2007, there is no scope of application of equitable doctrine against the
assessee and in favour of the Revenue on the ground that it will amount to conferring of double benefit.
The moment sub-rule (5C) was introduced, the Legislature made its intention clear that from the date of
coming into force of the said amended rule, in case of future remission on the ground mentioned in the
said sub-rule, there will be reversal of the credit.
18. The dispute in the present matter relates to the goods cleared for export
vide ARE-1 No. 26/2010-11, dated 13.07.2010. Thus the Notification No. 33/2007-C.E.
(N.T.), dated 7.9.2007, is applicable to this case. From the impugned it is apparent that
the appellant, on being pointed out by Audit, has paid the Central Excise duty
amounting to Rs. 1,46,357/- vide Debit Entry no. 2276, dated 06.03.2012 and paid
interest of Rs.38,145/- vide challan No. 01300, dated 06.03.2012 in PLA. However, the
appellant has not reversed the input Credit involved in the goods lost in sea due to the
accident. In light of the above discussion and the incorporation of Rule 3 (5C) of the
Cenvat Credit Rules, 2004, vide Notification no. 33/2007-C.E. (N.T.),dated 7.9.2007, it
is clear that once remission of duty with respect to the final products destroyed, is
ordered to be given, the Cenvat Credit involved in the inputs is required to be reversed.
Further, the appellant has already been compensated for the total assessable value of
9 F.No. V.2(84)42/Ahd - I/2013
the goods amounting to Rs.14,20,940/- by the insurance company, as such the
appellant cannot be allowed to gain dual benefit by not reversing the Cenvat Credit on
inputs. Thus the appellant is invariably required to reverse the Cenvat credit on inputs
involved in the goods lost in sea in transit.
19. Rule 21 of the Central Excise Rules, states that "Where it is shown to
the satisfaction of the Commissioner that goods have been lost or destroyed by
natural causes or by unavoidable accident or are claimed by the manufacturer as unfit
for consumption or for marketing, at any time before removal, he may remit the duty
payable on such goods, subject to such conditions as may be imposed by him by
order in writing."
20. In view of the above discussion, I find that the appellant is eligible for
remission of duty, subject to the condition that the Cenvat Credit of inputs involved in
their finished goods is reversed by the appellant. Therefore, I pass the following order:
ORDER
21. In view of the above, I allow the appeal filed by the appellant subject
to the condition stated above and set aside the impugned •rder.
(ANIL KUMAR) 9.2 \))
COMMISSIONER (APPEALS-V),
CENTRAL EXCISE,
AHMEDABAD.
Date: /01/2014
TTESTED Y
( .P.Vyas) Superintendent (Appeals-V) Central Excise, Ahmedabad.
To M/s. Prasad GWK Cooltech Pvt.Ltd., Plot no. 4, A-4, Phase-I, GIDC Estate, Vatva, Ahmedabad
Copy to: 1. The Chief Commissioner, Central Excise, Ahmedabad Zone, Ahmedabad 2. The Commissioner of Central Excise, Ahmedabad-I,
3. The Deputy/Assist. Commissioner, Central Excise, Division-II, Ahmedabad-I.
y4,. The Superintendent (System), Central Excise, H.Q., Ahmedabad-I for
uploading the order on web site.
5. PA to Commissioner (Appeals-V)
6. Guard File.