JUDGMENT

Mohammad Rafiq, J. - Since the issues involved in all the aforesaid three appeals are same and they arise out of common judgment, therefore, they were heard together and are being decided by this common judgment.

2. These appeals have been filed by the appellant Rajasthan Small Industries Corporation Limited under section 130(1) of the Customs Act, 1962 (for short 'the Act') challenging the common judgment dated 30.12.2016 passed by Customs, Excise & Service Tax Appellate Tribunal, New Delhi (for short 'the Tribunal') whereby the appeals filed by the appellant have been dismissed and adjudication orders passed by the Commissioner of Customs dated 06.11.2012, 01.03.2013 and 19.08.2013 have been confirmed.

3. The aforesaid appeals were admitted by this Court vide order dated 15.11.2017 on the following substantial questions of law:

In DB Custom Appeal No. 3/2017 :-

"(i) Whether on the facts and in the circumstances of the case and in law the Hon'ble CESTAT was justified in confirming that the demand of Rs. 1,71,47,255/-along with interest as cost recovery charges raised by ld. Commissioner of Income Tax under the provisions of regulation 5(2) read with regulation 6(1)(o) of t