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th-1-4-F ei &cLU : File No : V2(84) 42 /Ahd-l/2013

6

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

41- Mr4"a" TOW 3Trs-dTr (3rET'FF-V) -rTr trritff

Passed by Shri. Anil Kumar, Commissioner (Appeal -V)

Tr Asst./Deputy Commissioner, *-4171 Div. - II A'bad - I gT7-r 7Ttf 3-1T 4T

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

311trF 3-1T -VT 3TTtd)-tT 311417 u6 3Tr47-r of zrziTRP-rit

-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 :

(1) ■ 0-11q•-i cK 3-1111i, 1994 ch) z-113T 31-dff TdT7 117 ITPTA r-E40 al-RT cr))

I2T Z 3t-d-TIT 3-4taTur 31-T49 3Tt9 . 11-RU flct>k,

-ftl-Tp-r, -410'r 41141, : 110001 0,1 -er 7rt -rft-

(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 :

(ii) zit 4 Trwr 4 vi.si com_14 #,:ruFrF Trr mAi4 # 111

1.17:WTFR WWTIR 4 +11 d v11 4-11'1 trr Tri ITizr— R A ci6

4)1 # TIT f 4-1133TTIR 4116 4 crf —zrr tr

(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.

(f) 41TRT f+--# "TNzrr crk-vr 4-i I d ER TIT +-II \3 ,41 Icryc=.1

ft-4-d *19-rF0 zrT fTIK Tfr v--tzr 4 1-1Dci t

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.

\Ict-ii‹.-1 4 \10-114-1 71T-Tff f vil 91-4 1 t.31)-- t# 3TT-471 *tr MT f9Tf7f 711 3171-4T, arta. 5 NI ITTRd. ArW9-4 TR Trf Ell f4-di 31i 7:lif (r.2) 1998 zrru los gki f1--s-wr ft7 "77 erl

(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.

(1) M\ —414 \3c414 -1 (31.0)-6) 1 4 111c1A, 2001 f9-49 9 3iTTIT f4fe41Z TFE -i-11C0:11 V-8 AftZtt 31-rtzr (1)1 Jiro tei—ai-r- r 74 aIrtita- 31-1tZE 4 tr—tr

gf'd4I* 31T-4.-4-9 it-41. v11-11 I ■itl 374 R3T9T Th-T ITC-QTeRi at-Tf--a tTRT f4Z1-1-ftffi c 1171-M9 3-1-121 t13117-6 -cl 1 ei 1 -1 mt

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

3 cMcf f ei 1-1R-ck 2 (1) Z A ETC` 31.T.47 3TFTT Z 31ta) AP-1-- A 4111.1

311).-jrzt RfrzrarTRUT cftfitz) c zrft-4# a)-41-zi Irftwr, 3T-6#-4-r-orq 3t1-20,

6 0-LI t c1) 44-11 ■3u.4, Araut -14H, 3T611411q-380016.

(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.

(2) ---41-TT (311:11F) 1-- -1 411c1A, 2001 Tet UTRT 6 T 3le-1 1 1e-I A .7-3 A f4-ii -ffu ft -q

311:11AR1 31-trF f 3TL1FF f 311tZT 1 u i c vrd-zrr w s i ∎RLI I

V4T . (.6) 9I 4 1 3117 d+Ilql +RI I T1.1.9.1 5 'FM. zit \31'1 cb 4-1 cI6i 1000 / — thaRi 4-Alt

tit I ■3-I \3041q +1i +I, 'gifT7 c1 411 , 1 31117 (-1 4 1P11 VII T=1f9T .-1717 5 1T ZIT 50 'FM Oct) T .d)

R 5000 / — thti tt I Lrigi \INN TETTT, .117 4 *A- 31-17 el 4 1 I e,11 4 N-11 T(191 \h)LIK 50

.T.qff ZIT \3tI-11 Lrzii I ci i 7 10000 / — .chRT ertI 4 rftRi 6P4ch 7).

I Trtf A ,z-kiq mr't ■3t1 91-Pro- 40 4

IN_q I T ef ■516'1 3-4T1 c) Rkl-d" I N4 fP 3TTk-47— Tri7 500 / — thil7T

-Tft I

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/-.

Tit 311kzr A co tqf 61 e1 I t 31r4zr fa7 Ebti 4,1

f+-zrT \311.-11 .Fft. Mzi 6)e) V '1-i)f '12 1T .L1 r). T-14 f z12TTftelft 31 A-4

-Z1V41{cfrO0 l (41 31tc TIT *41-Z1 ' -kc#, N ch) l cb 3Tfk-4-ff F+--zrr vi l c1 I t

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

tm-z

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.

*.-r 3117 ti4f4d - ct)) f4-zot . c't 3117 'ITC aFM 311ffrr ,flor 7tFTT

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.