Madras High Court
M/S.Steel Authority Of India Limited vs Office Of The Commissioner Of Gst & Ce on 22 November, 2023
Author: Krishnan Ramasamy
Bench: Krishnan Ramasamy
Writ Petition No.12074 of 2023
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED : 22.11.2023
CORAM
THE HONOURABLE MR.JUSTICE KRISHNAN RAMASAMY
Writ Petition No.12074 of 2023
and
W.M.P.No.11916 of 2023
M/s.Steel Authority of India Limited
Salem Steel Plant
Salem - 636 013.
represented by Mr.JV Sivakumar,
General Manager (Finance & Accounts) ... Petitioner
Vs.
1.Office of the Commissioner of GST & CE,
GST Bhawan, No.1, Foulkes Compound,
Anaimedu, Salem - 636 001.
2.Office of the Assistant Commissioner of GST & CE,
106, 3rd Floor, Varalakshmi Orchid,
Ramakrishna Road, Salem - 636 007.
3.Office of the Superintendent of Central Excise,
Salem III Range,
No.15, 1st Floor, Rajaramnagar Main Road,
Sahadevapuram, Salem - 636 007.
4.The Central Board of Indirect Taxes and Customs,
1/22
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Writ Petition No.12074 of 2023
Department of Revenue, Ministry of Finance,
Government of India (Through its Chairman),
North Block, New Delhi - 110 002.
5.Union of India
represented by its Under Secretary,
Ministry of Finance, Department of Revenue,
North Block, New Delhi - 110 001. ... Respondents
PRAYER: Writ Petition filed under Article 226 of the Constitution of
India praying to issue a Writ of Certiorari calling for the records relating
to the Show Cause Notice No.10/2011 with C.No.V/73/15/172/2008 - C.
Ex., Adj dated 09.03.2011 as amended by the Corrigendum bearing DIN
20230259XP000021792D dated 24.01.2023 issued in the impugned
Show Cause Notice Sl.No.10/2011 (ADC) dated 09.03.2011 by the first
respondent and quash the same.
For Petitioner : Mr.Raghavan Ramabadran
For Respondents : Mr.S.R.Sundar
Senior Standing Counsel [R1 to R4]
*****
ORDER
The present writ petition has been filed challenging the Show
Cause Notice dated 09.03.2011 issued by the first respondent.
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Writ Petition No.12074 of 2023
2. The brief facts of the case is as follows:
2.1. The petitioner is the manufacturer of Cold Rolled Stainless
Steel (CRSS) Sheets and Coils. The petitioner receives purchase orders
from various Co-operative Unions for Stainless Steel milk cans
conforming to desired specifications. The petitioner does not directly
undertake the manufacture of these milk cans as their factory under the
above Central Excise Registration does not have the necessary facility to
manufacture milk cans. Therefore, the petitioner utilizes the services of
M/s.Oscar Indus to fulfill such orders, a Small Scale Industry ("SSI") job-
worker. The petitioner executes purchase orders with job-worker for
manufacturing milk cans from the CRSS Sheets and Coils. The petitioner
dispatches CRSS Sheets and Coils to the job-worker after payment of
excise duty under Rule 11 of the Central Excise Rules, 2002. The job-
worker manufactures the milk cans, after which the milk cans are either
cleared to the petitioner or directly to the customer. When the job-worker
clears the milk cans directly to the customer, the petitioner would
reimburse the freight and delivery charges to the job-worker upon
production of proof of delivery to the petitioner. The job-worker then
raises an invoice for the conversion charges on the petitioner.
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Writ Petition No.12074 of 2023
Subsequently, the petitioner raises an invoice on the customers for the
milk cans. No excise duty is charged or reflected on this commercial
invoice as the milk cans are NIL rated.
2.2. An EA 2000 Audit was conducted in the petitioner's premises
from 25.05.2006 to 30.05.2006 and the petitioner's accounts for the
period from December 2005 to March 2006 were audited by the Internal
Audit Department of the first respondent. The petitioner received the
audit objections from the third respondent, wherein it is stated that duty
had not been paid on the branded goods by the job-worker and no
evidence had been provided for payment of duty on the milk cans
manufactured by Oscar Indus. The audit objections also requested the
petitioner to direct Oscar Indus to pay the duty and to submit proof. The
petitioner responded to the audit objections stating that the milk cans are
kitchen utensils subject to Nil rate of duty vide Notification No.10/2003 -
CE 01.03.2003 and thus, there can be no excise duty levied on the
manufacture of milk cans.
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Writ Petition No.12074 of 2023
2.3. Thereafter, the impugned show cause notice was issued by the
first respondent proposing to demand excise duty of Rs.11,29,864/- on
the milk cans cleared from 2005-06 to May 2008 along with interest
u/s.11-AB of the Central Excise Act, 1944 [for brevity 'the Act'] and
penalty under Section 11-AC of the Act. The show cause notice also
proposed to invoke extended period of limitation under Section 11-A of
the Act alleging that the petitioner had suppressed the facts regarding the
manufacture and clearance of milk cans to the knowledge of the first
respondent.
2.4. The petitioner submitted a reply dated 25.04.2011 to the
impugned show cause notice praying that the proposals in the impugned
show cause notice be dropped and that the petitioner be granted an
opportunity of personal hearing before the impugned show cause notice is
adjudicated. Thereafter, the impugned show cause notice was never
broached by the respondents. Hence, the petitioner was of the bonafide
belief that the petitioner's reply had been accepted and the proceedings
initiated under the show cause notice had been closed.
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Writ Petition No.12074 of 2023
2.5. A corrigendum was issued to the impugned show cause notice
and the same was received by the petitioner on 11.02.2023, wherein it is
stated that the second respondent would now be the adjudicating
authority. This was the first communication regarding the impugned
show cause notice ever since the reply was filed on 25.04.2011.
2.6. To the shock of the petitioner, the petitioner received a
personal hearing notice on 11.03.2023 stating that the impugned show
cause notice was being posted for personal hearing on 24.03.2023,
28.03.2023 and 31.03.2023 before the second respondent. The petitioner
was required to attend the personal hearing on any one of the above dates
and in the event of failure, the matter would be decided ex parte on the
basis of the documents available on record. Since the impugned show
cause notice pertained to transactions which transpired 12 years ago, the
petitioner requested the first respondent for time to gather information
and records available vide letter dated 17.03.2023, which has been
acknowledged by the second respondent, but, no response has been
received by the petitioner till date. Left with no other option, the
petitioner has filed the present writ petition.
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Writ Petition No.12074 of 2023
3. Heard Mr.Raghavan Ramabadran, learned counsel for petitioner
and Mr.S.R.Sundar, learned Senior Standing Counsel appearing for
respondents 1 to 4.
4. Learned counsel for petitioner submitted that the impugned
show cause notice was issued on 09.03.2011 and the personal hearing
notice was issued on 11.03.2023. The act of scheduling personal hearing
on 24.03.2023 after a lapse of 12 years and 15 days, reckoned from
09.03.2011 (date of issuance of show cause notice), amounts to
inordinate delay in adjudication. Such delay is fatal to the proceedings
and that the show cause notice merits to be quashed on this ground alone.
Learned counsel further submitted that Section 11A(2A)(a) of the Act as
it existed during the impugned period, contemplated a time limit of one
year for the Central Excise Officer to determine the amount of duty where
it was not paid or short-levied by reason of fraud, collusion or any other
willful mis-statement or suppression of facts. Admittedly, Section
11A(2A) of the Act prescribed the above time lines to be followed "where
it is possible to do so". Even assuming, there was some impossibility in
adjudicating the show cause notice, a delay of 12 years is unreasonable
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Writ Petition No.12074 of 2023
and completely unfair. Learned counsel further submitted that Section 11-
A of the Act was substituted vide Finance Act, 2011, w.e.f. 08.04.2011
and Section 11-A(11) of the Act prescribed clear time lines for
determination of excise duty after issuance of notice. As last amended
w.e.f. 14.05.2016, Section 11A(11)(b) of the Act prescribed that a
Central Excise Officer shall determine the amount of duty due within two
years where the duty was not paid or short-levied by reason of fraud,
collusion or any other willful misstatement or suppression of facts.
Further, prior to stipulation of such time lines in the Act, the principle of
timely adjudication of the matter was provided in the Circulars. The
fourth respondent had issued Circular No.223/8/85-CX dated 21.03.1985
stipulating a maximum time frame of six months for adjudication of
disputes to be calculated from the time of issuance of show cause notice.
The same principle stood reiterated in Circular No.20/92-CS dated
12.12.1992 and subsequently, in Circular No.1053/02/2017-CX dated
10.03.2017.
5. In support of his contention, learned counsel placed reliance on
various judgments of the other High Courts as well as this Court. Learned
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counsel placed strong reliance on the judgment of this Court in M/s.Steel
Authority of India Limited v. Office of the Assistant Commissioner of
GST [2022 (11) TMI 1393] and the judgment of the Bombay High Court
in Raymond Ltd. v. Union of India [2019 (368) ELT 481 (Bom.)].
Submitting as above, learned counsel prays for quashing the impugned
show cause notice.
6. Per contra, learned counsel for respondents submitted that the
present matter was kept in the Call Book pursuant to the circular issued
by the department and hence, the delay has occurred. When this Court
posed a question as to whether intimation was provided to the petitioner,
learned counsel for respondents fairly submitted that no such intimation
was provided to the petitioner.
7. Relying on the counter affidavit, learned counsel submitted that
though the audit objections were contested by the respondents, the show
cause notice was issued as a protective measure. The show cause notice
was ordered to be transferred into call book category based on the
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Board's Circular No.162/73/1995-CX dated 14.12.1995, as the issue
pertains to the petitioner herein falls under category (iii), which deals
with cases where audit objections are contested by the then
Commissioner on 18.05.2009. Further, there were no statutory obligation
on the part of the respondents herein to inform the petitioner about the
transfer of their case into the call-book category as the same was
introduced only in the year 2017. Thus, the respondents have not violated
any of the provisions in transferring the case of the petitioner into call-
book category based on the board circular. Learned counsel further
submitted that Clause (a) of Section 11A(11) of the Act clearly stipulates
that the Central Excise officer shall determine the amount of duty under
sub-section 10, within one year from the date of notice where it is
possible to do so. Therefore, the time limit is not applicable to all the
cases and it is applicable only to the show cause notices where the
adjudicating authority was able to decide the cases. In the instant case,
the Central Excise Officer was not in a position to adjudicate the cases as
the department contested the issue with the Audit as there were audit
objections. Therefore, the cases were transferred to call book as per the
instructions issued therein. Hence, it is not mandatory for the respondents
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herein to decide all the cases within one year from the issue of notice. In
other words, the time limit is dependent on the circumstances of the case.
In view of the same, the adjudicating authority has not deliberately
delayed the adjudication proceedings. Hence, the time limit prescribed
u/s.11A(11)(b) of the Act, is not applicable to the show cause notice in
question.
8. Learned counsel further submitted that all audit objections
relating to Central Excise and Service Tax issued prior to 01.03.2014
shall be compared with the pending Action Taken Notes (ATNs),
received from the office of CAG, enclosed as Annexure B with the
Circular. For customs, the list shall be separately issued. Show Cause
Notices (SCNs) relating to audit objections figuring in the list should not
be adjudicated and further action may be taken on them in consultation
with the Commissioner (PAC). The rest of the objections stand finally
vetted by CAG Audit with no further comments which means that the
reply of the department has been accepted by the CAG office. Show
Cause Notices relating to these objections may be taken up for
adjudication on merits, including those in the call-book, following the
procedure prescribed. Submitting as above, learned counsel prays for
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Writ Petition No.12074 of 2023
dismissal of the writ petition.
9. This Court has considered the rival submissions and perused the
materials available on record.
10. The central issue to be decided in the present case is whether
the proceedings is barred by limitation or not ?
11. A show cause notice was issued on 09.03.2011 by the
respondents and a reply was filed by the petitioner on 25.04.2011. After a
period of 12 years, a personal hearing notice was issued by the
respondents to the petitioner to appear for personal hearing on
09.03.2023. The main grievance of the petitioner is that after a period of
12 years, the respondents have no locus standi to proceed against the
petitioner. At this juncture, it would be appropriate to examine the time
limit provided in the Act with regard to determination of duty by the
Central Excise Officer.
12. Section 11A(11) of the Act reads as follows:
"(11) The Central Excise Officer shall determine the amount of
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duty of excise under sub-section (10) -
(a) within six months from the date of notice where it is possible
to do so, in respect of cases falling under sub-section (1);
(b) within [two years] from the date of notice, where it is possible
to do so, in respect of cases falling under sub-section (4)."
13. The petitioner falls under Section 11(b) of the Act. Therefore,
the respondents are supposed to have determined the amount of duty
within a period of two years. Merely because the words "where it is
possible to do so" are provided in the Act, it does not mean that they can
take their own time to determine the excise duty. It must be done within a
reasonable time i.e. within one or two years. In the present case, the delay
is more than 12 years, which is an inordinate one.
14. The Government of India issued a circular dated 21.12.1992,
which reads as follows:
"Circular : 20/92-CX.6 dated 21-Dec-1992
Adjudication - Time limit for finalisation of
Circular No.20/92-CX.6, dated 21-12-1992
[From F.No.213/28/92-Cx.6]
Government of India
Ministry of Finance (Department of Revenue)
Central Board of Excise & Customs, New Delhi
Subject : Time period for finalisation of Adjudication -
Regarding.
The Trade has been represented in the meeting of the 33rd
Advisory Council that they are facing problems due to the
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inordinate delays in the adjudication of cases. The Board's
D.O.F.No.223/8/85-CX.6, dated 21-3-1985 had already
stipulated a maximum period of 6 months from the date of issue
of show cause notice within which the case is to be decided. It
may be ensured that, as far as possible, this limit is adhered to.
2. The above instructions should be brought to the notice of
the Trade and field formations through appropriate Trade Notices
and circulars."
15. In the aforesaid circular, it is clearly stated that the Board's
D.O.F.No.223/8/85-CX.6, dated 21-3-1985 had already stipulated a
maximum period of 6 months from the date of issue of show cause notice
within which the case is to be decided and as far as possible, this limit is
to be adhered to. The said circular is in force as on today.
16. It is seen that instructions were also issued by the Ministry of
Finance, Department of Revenue, Central Board of Excise & Customs on
17.09.2015, to streamline the process of adjudication since the High
Court has passed orders on the aspect of delay in completing the
adjudication and due to receipt of complaints from assesses from time to
time. The instruction dated 17.09.2015 reads as follows:
"Sub : Streamlining the process of adjudication
It has come to the notice of the Board that Hon'ble High Court of
Bombay in its judgment dated 15.07.2015 in the case of Lanvin
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Synthetics Pvt. Ltd. and another Vs Union of India in
W.P.No.1536 of 2014 [2015-TIOL-1668-HC-MUM-CUS] has
quashed the Show Cause Notice dated 13.03.1997 and prohibited
the department from passing any adjudication order as the Show
Cause Notice was not adjudicated for 17 long years as no records
were available. The High Court in its orders at para 12 has
observed:
"If law postulates early end to such proceedings and there is no
period of limitation prescribed, does not mean that the proceedings
initiated could be concluded at the sweet will and fancies of the
department."
2. The High Court in para 11 of said order has further quoted
Hon'ble Supreme Court in the case of Citedal Fine
Pharmaceuticals [2002-TIOL-680-SCCX] where the Apex Court
was pleased to hold that in the absence of any period of limitation,
it is settled law that every authority should exercise the power
within a reasonable period.
3. It is painful to note that in spite of various monitoring
mechanisms in existence, such occurrence could not be avoided.
The matter has been viewed seriously and all the adjudicating
authorities are directed to pass adjudication orders within time
limits as prescribed, so that the above said instance is not repeated
in future.
4. Further, I am directed to refer to Board letter
F.No.275/17/2015-CX.8A dated 11.03.2015 (copy available on
CBEC website), on the subject of 'Steps needed to be taken to
improve tax administration;, wherein the need for passing the
adjudication order within the specified time has been emphasised.
5. All the Commissioners should also explore to possibility of
scanning and digitization of all papers connected with
adjudication and litigation matters.
6. Any other suggestion in this regard may be forwarded to this
office.
7. The above should be brought to the notice of the field
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formations under your charge for scrupulous compliance."
17. By virtue of the aforesaid circular, the respondents had viewed
the matter seriously and therefore, instructed all the adjudicating
authorities to pass adjudication orders within the time limit as prescribed
so that the above said mistake will not repeat in future.
18. In the present case, the reasons provided by the respondents
was that the present matter was kept in the call book and therefore, there
was a delay in completing the adjudication process. On this aspect, a
Division Bench of the Bombay High Court in the case in Raymond Ltd.
v. Union of India [2019 (368) ELT 481 (Bom.)] has passed a detailed
order and the relevant portions are extracted hereunder:
"6. We specifically asked Mr. Jetly, Learned Counsel
appearing for the Revenue, whether any intimation was given to
the petitioners either in 2001 or in 2013 that the show cause
notices are being kept in the call book and the reason for it i.e.
awaiting a final decision in the CERA audit objection and / or the
decision of the Apex Court in the appeal filed by the Revenue
from the order of the Tribunal in case of petitioners' Indore and
Bhopal Unit. Mr. Jetly very fairly states that no intimation of
keeping the show cause notices in the call book was given. Thus,
the occasion to give any reasons for it being kept in the call book
to the petitioner did not arise.
7. In the aforesaid facts, the issue that arises for our
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consideration is whether in the present facts, commencement of
adjudication proceedings after a long delay of 14 to 17 years is
justified when the party in all these years has not been put to
notice that the proceedings were kept in abeyance. In fact, this
Court, in the case of Bhagwandas Tolani (Supra) decided as far
back as 1982, has held that even if there is no time limit provided
in the statute for adjudication proceeding, yet it is not permissible
to commence adjudication proceeding after a long period of
10/15/20 years, particularly when the delay is not on account of
any default on the part of the answering party. It further held that
reopening of an adjudication proceeding after a long time would
cause serious prejudice to the parties, as in the meantime, the
relevant records may have been misplaced, the persons who were
in charge of the affairs relating to issue raised in the show cause
notice may no longer be available. Further, in Cambata
Industries Pvt. Ltd. v. Additional Dir. of Enforcement,
Mumbai, (2010) 254 ELT 269 (Bom.), this Court held that in
absence of any fault on the part of the petitioners, it is not open to
the Revenue to re-open proceedings after long delay without
justifiable reasons. In Hindustan Lever Limited v. Union of
India (2011) 264 ELT 173 (Bom.), this Court has observed as
under:-
“15. …...............
The weight of the judicial pronouncements lean in favour
of quashing the proceedings, if there has been an undue delay in
deciding the same. See Government of India v. The Citedal Fine
Pharmaceuticals, Madras and Ors., 1989 (42) E.L.T. 515 (S.C.)
and the judgment of the Division Benches of this Court in
Bhagwandas S. Tolani v. B.C. Aggarwal and Ors. reported in
1983 (12) ELT 44 (Bom.) and Universal Generics Pvt. Ltd. v.
Union of India reported in 1993 (68) ELT 27 (Bom.). The
underlying principle laid down in the said judgments is that in
absence of any period of limitation, it is required that every
Authority is to exercise the power within a reasonable period.”
8. Further, this Court in the case of M/s.Sanghvi
Reconditioners (supra) had occasion to consider an identical
submission as made before us by the Revenue i.e. show cause
notices had been kept in the call book as an identical challenge in
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case of another assessee was pending in the Hon'ble Supreme
Court. This defence on the part of the Revenue was negatived by
the Court. This on the ground that accepting such a stand on
behalf of the Revenue would defeat the rule of law itself. In fact,
the Court noted as under :-
“Secondly, we also omit totally from our consideration the
complaint of the petitioner that in a matter as old as of 1999, if
now the adjudication has to be held, it will be impossible for
them to trace out all the records and equally, contact those
officials who may not be in their service any longer. Thus, they
would have no opportunity, much less reasonable and fair, to
defend the proceedings. That is equally a balancing factor in the
facts and circumstances of the present case.”
9. In the present facts, it is the case of the petitioner that
because of long delay, papers and proceedings relevant to meet the
show cause notice are not available. Thus, seriously hampering
the petitioners to appropriately meet the show cause notice. This
delay in taking up the adjudication of the show cause notice (in
the absence of any fault on the part of the party complaining) is a
facet of breach of principles of natural justice. It impinges on
procedural fairness, in the absence of the party being put to notice
that the show cause notices will be taken up for consideration,
after some event and / or time, when it is not heard in a reasonable
time. In the absence of the above, particularly as in this case, long
delay has resulted in papers being misplaced. The reasonable
period may vary for case to case. However, when the notices are
being kept in abeyance (by keeping them in the call book as in
this case), the Revenue should keep the parties informed of the
same. This serves two fold purpose One it puts the party to notice
that the show cause notice is still alive and is only kept in
abeyance. Therefore, the party can then safeguard its evidence, till
the show cause notice is taken up for adjudication. Secondly, if
the notices are being kept in the call book for some reason, the
party gets an opportunity to point out to the Revenue that the
reasons for keeping it in call book are not correct and the notices
could be adjudicated upon immediately. This is the transparent
manner in which the State administration must function.
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10. In fact, we note that the above manner of functioning is
the objective of the State administration, as our attention has been
drawn to the C.B.E. & C. Circular No.1053/2/2017-CX., dated
10/03/2017. In paragraph 9.4 of the above circular of C.B.E. &
C. has directed the officers of the department to formally
communicate to the party that the notices which have been issued
to them, are being transferred to the call book. This would be
expected of the State even in the absence of the above circular; the
circular only states the obvious. In this case, the show cause
notices were kept in the call book not at the instance of petitioner,
but by the Revenue of its own accord. After having kept it in the
call book, no intimation/communication was sent by the
Commissioner pointing out that the show cause notices had been
kept in the call book. Thus, bringing it to the notice of the
petitioners that the show cause notices are still alive and would be
subject to adjudication after the show cause notices are retrieved
from the call book on the dispute which led to keeping it in the
call book being resolved. This, admittedly has not been done by
the Revenue in this case.
11. Therefore, it was reasonable for the petitioners to
proceed on the basis that the department was not interested in
prosecuting the show cause notices and had abandoned it. These
proceedings are now being commenced after such a long gap, after
having led the petitioner to reasonably expect that the proceedings
are dropped. Therefore, even if, notices can be kept in the call
book to avoid multiplicity of the proceedings, yet the principle of
natural justice would require that before the notices are kept in the
call book, or soon after the petitioners are informed the status of
the show cause notices so as to put the parties to notice that the
show cause notices are still pending. Giving notices for hearing
after gap of 17 years, as in this case, is to catch the parties by
surprise and prejudice a fair trial, as the documents relevant to the
showcause notices are not available with the petitioners."
19. In the present case, admittedly no intimation was provided to
the petitioner with regard to keeping the call book and even in that case
also, the Act provides time limit of six months to pass orders. However, in
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the present case, citing the internal circular issued by the respondents to
keep the matters in the call book, the respondents have failed to adhere to
the time limit provided in the statute. The circular is beyond the scope of
the provisions of the Act and notifications provided therein. Therefore,
keeping the call book without intimation to the petitioner and beyond the
scope of the Act is unacceptable. Hence, by citing the said reason, the
respondent department cannot keep the matter pending for a period of 12
years and thus, the present proceedings is clearly barred by limitation.
20. This Court, in M/s.Steel Authority of India Limited v. Office
of the Assistant Commissioner of GST [2022 (11) TMI 1393], has held
as follows:
"29. The Gujarat High Court in the case of Siddhi Vinayak
Syntex Pvt. Ltd. Vs. Union of India, [(2017) 352 ELT 455],
considered the case of delay ranging up to 15 years in that case
and had set aside all SCNs as being unreasonably and unduly
belated. The Bench has also expressed the view that the concept of
the call book, created by the Central Board of Excise and
Customs, and transfer of pending cases to the call book, is
contrary to the statutory mandate. Such transfer provides for an
extrastatutory period of limitation, impermissible and contrary to
law."
21. In view of the above and the law laid down by various Courts
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as well as this Court, this Court is of the considered view that present
proceedings could not be allowed to continue after a period of 12 years,
particularly, when there is no mistake on the part of the petitioner.
Adjudication of proceedings after a long period would cause serious
prejudice to the parties. Hence, this Court holds that the present
proceedings is barred by limitation and is unjustifiable.
For the aforesaid reasons, this Writ Petition is allowed and the
Show Cause Notice dated 09.03.2011 issued by the first respondent, is
hereby quashed. No costs. Consequently, connected miscellaneous
petition is closed.
22.11.2023
Index: Yes/No
Speaking Order/Non-speaking Order
Neutral Citation: Yes/No
gm
KRISHNAN RAMASAMY, J
gm
To
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1.The Office of the Commissioner of GST & CE,
GST Bhawan, No.1, Foulkes Compound,
Anaimedu, Salem - 636 001.
2.The Office of the Assistant Commissioner of GST & CE,
106, 3rd Floor, Varalakshmi Orchid,
Ramakrishna Road, Salem - 636 007.
3.The Office of the Superintendent of Central Excise,
Salem III Range,
No.15, 1st Floor, Rajaramnagar Main Road,
Sahadevapuram, Salem - 636 007.
4.The Central Board of Indirect Taxes and Customs,
Department of Revenue, Ministry of Finance,
Government of India (Through its Chairman),
North Block, New Delhi - 110 002.
Writ Petition No.12074 of 2023
22.11.2023
https://www.mhc.tn.gov.in/judis
