CUSTOMS, EXCISE AND SERVICE TAX APPELLATE TRIBUNAL MUMBAI WEST ZONAL BENCH EXCISE APPEAL NO: 85810 OF 2025 [Arising out of Order-in-Original No: PUN-EX-CGST-I-MK-COM-03/2024-25 dated 26^th November 2024 passed by the Commissioner of CGST & Central Excise, Pune – I.]

Danfoss Systems Limited

145 Off Mumbai – Pune Road, Pimpri, Pune - 411018 … Appellant versus Principal Commissioner of CGST & Central Excise Pune – I

41-A ICE House, Sassoon Road, Pune - 411001 …Respondent APPEARANCE:

Shri Prakash Shah, Senior Counsel with Shri Mihir Mehta, Advocate for the appellant Ms Prakriti Nigam, Joint Commissioner (AR) for the respondent CORAM:

HON’BLE MR C J MATHEW, MEMBER (TECHNICAL) HON’BLE MR AJAY SHARMA, MEMBER (JUDICIAL)

FINAL ORDER NO: 85094/2026 DATE OF HEARING: 04/08/2025 DATE OF DECISION: 22/01/2026 PER: C J MATHEW M/s Danfoss Systems Limited, canvassing against erroneous application of law in recovery of CENVAT credit of ₹ 2,41,49,130, along with applicable interest, under rule 14 of CENVAT Credit Rules, 2004 and penalty of like amount under rule 15 of CENVAT Credit Rules, 2004, is before us for the second time; on the earlier occasion, and in the name and style of Eaton Fluid Power Ltd, the