2026:BHC-OS:3444 IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION CENTRAL EXCISE APPEAL NO.9 OF 2025 Commissioner of Central Excise and ST CGST and Central Excise Daman, Vapi .. Appellant.

Versus KEC International Ltd. .. Respondent.

Digitally signed by SMITA SMITA RAJNIKANT RAJNIKANT JOSHI Adv. Maya Majumdar with Adv. Niyati Mankad and Adv. Priyanka Date:

JOSHI 2026.02.05

17:55:05 Singh, for the Appellant.

+0530 Adv. Bharat Raichandani with Adv. Bhagrati Sahu i/b. UBR Legal, for the Respondent.

CORAM: B. P. COLABAWALLA &

FIRDOSH P. POONIWALLA, JJ.

DATE: FEBRUARY 04, 2026 P. C.

1 The above Appeal has been filed by the Revenue contending that certain substantial questions of law arise from the impugned Order dated 7^th June, 2024 passed by the CESTAT. Though, several questions have been raised in the Memo of Appeal, the learned Counsel appearing on behalf of the Revenue pressed into service only questions (1) and (2), which read thus:-

“1:-Whether the CESTAT has erred in holding that there was a substantial compliance of the provisions of the exemptions notifications under reference and the substantial benefit could not be denied merely for procedural lapse?

2 Whet