IN THE CUSTOMS, EXCISE AND SERVICE TAX APPELLATE TRIBUNAL EASTERN ZONAL BENCH : KOLKATA REGIONAL BENCH – COURT NO. 1 Excise Appeal No. 75672 of 2024 (Arising out of Order-in-Appeal No.82/GHY(A)/COM/CEX/DIB/2024 dated 12.02.2024 passed by Commissioner of Central Goods and Service Tax & Central Excise, Guwahati)

M/s. Hindustan Unilever Ltd. : Appellant Personal Product Factory, Unit-I, P.O.-Doomdooma, Dist.-

Tinsukia, Assam-786 151 VERSUS Commissioner of Central Goods & Service Tax & : Respondent Central Excise, Guwahati Guwahati Commissionerate, Housefed Complex, Dispur-

Beltola Road, Dispur, Guwahati-781 006.

With Excise Appeal No. 75673 of 2024 M/s. Hindustan Unilever Ltd. : Appellant Personal Product Factory, Unit-I, P.O.-Doomdooma, Dist.-

Tinsukia, Assam-786 151 VERSUS Commissioner of Central Goods & Service Tax & : Respondent Central Excise, Guwahati Guwahati Commissionerate, Housefed Complex, Dispur-

Beltola Road, Dispur, Guwahati-781 006.

With Excise Appeal No. 75674 of 2024 M/s. Hindustan Unilever Ltd. : Appellant Personal Product Factory, Unit-I, P.O.-Doomdooma, Dist.-

Tinsukia, Assam-786 151 VERSUS Commissioner of Central Goods & Service Tax & : Respondent Central Excise, Guwahati Guwahati Commissionerate, Housefed Complex, Dispur-

Beltola Road, Dispur, Guwahati-781 006.

APPEARANCE:

Shri MH Oatil, Shri Viraj Reshomurula, Advocates & Shri Krupa Shah, Consultant, for the Appellant Shri Mihir Bondhopadhyay, Spl. Counsel for the Respondent CORAM:

HON’BLE SHRIASHOK JINDAL, MEMBER (JUDICIAL)

HON’BLE SHRI K. ANPAZHAKAN, MEMBER (TECHNICAL)

FINAL ORDER NO. 75141-75143/ 2026 DATE OF HEARING :21.01.2026 Order : [Per Shri Ashok Jindal]

The appellant has filed these 3 appeals which are having a common issue therefore, all are disposed of by a common order.

2. The facts of the case are as under:

2.1 The Appellants are engaged inter-alia in manufacture of Oral Preparations, Cosmetics, Hair Care & Skin Care Preparations, falling under Chapters 33 & 27, in their factories located at Doomdooma Estate, Dist. Tinsukia, Assam, known as Unit-I, Unit-II and Unit-III.

(1) On 20th November 1997, the Central Government announced an Industrial Policy, inviting entrepreneurs to set up new industrial Units in North-Eastern States and promised that such Units would be exempt from payment of central excise duty and income tax for a period of 10 years from the date of commencement of their commercial production. The Ministry of Industry notified the Industrial Policy on 24th December 1997.

(ii) In order to aid industrial growth in various non- developed areas of the country, including north- eastern States, Central Govt. issued Notifications granting exemption from payment of central excise duty on the goods manufactured in such areas.

(iii) Accordingly, inter-alia Notification No.32/1999- CE dated 08.07.1999 was issued granting exemption from duty of excise or additional duty of excise equivalent to the amount paid from PLA, by way of refund of such duty paid from PLA, after exhausting the Cenvat credit balance.

2.2 Similar Notifications No.56/2002-CE and 57/2002 both dated 14.11.2002 for Jammu & Kashmir, No.56/2003-CE dated 10.06.2003 and No.71/2003-

CE dated 09.09.2003 for Sikkim, etc. were issued.

2.3 The said basic Notification No.32/99-CE Ibid was amended by Notification No.17/2008-CE dated 27.03.2008 and Notification No. 31/2008-CE dated 10.06.2008 providing for fixation of special rate, if the manufacturer finds that actual value addition of the goods is more than 115% of the percentage prescribed in the Notification; for which an application to the Commissioner was to be made, not later than 30th September of the respective financial years.

2.4 Succeeding Notn. No.20/2007-CE dated 25.04.2007 was issued operative for the period 01.04.2007 providing exemption alike Notification No.32/99-CE dated 08.07.1999. This Notification was also amended by Notn.No.20/2008-CE dated 27.03.2008 and No.38/2008-CE dated 10.06.2008, providing for fixation of special rate, if the man