IN THE CUSTOMS, EXCISE AND SERVICE TAX APPELLATE TRIBUNAL EASTERN ZONAL BENCH: KOLKATA REGIONAL BENCH – COURT NO. 1 Excise Appeal No. 76209 of 2018 (Arising out of Order-in-Original No. 27/COMMR/BOL/17-18 dated 16.01.2018 passed by the Commissioner of Central Goods & Services Tax, Bolpur Commissionerate, Nanoor Chandidas Road, Sian, Bolpur, District: Birbhum, West Bengal, PIN – 731 204) M/s. Haldia Steels Limited (Unit-II) : Appellant Raturia Indusrial Area, Angadpur, D urgapur, West Bengal – 713 215 VERSUS Commissioner of Central Goods and Services Tax : Respondent Bolpur Commissionerate, Nanoor Chandidas Road, Sian, Bolpur, District: Birbhum, West Bengal - 731 204 AND Excise Appeal No. 76210 of 2018 (Arising out of Order-in-Original No. 27/COMMR/BOL/17-18 dated 16.01.2018 passed by the Commissioner of Central Goods & Services Tax, Bolpur Commissionerate, Nanoor Chandidas Road, Sian, Bolpur, District: Birbhum, West Bengal, PIN – 731 204) Shri Satpal Bansal, Director, : Appellant M/s. Haldia Steels Limited (Unit-II)

Raturia Indusrial Area, Angadpur, D urgapur, West Bengal – 713 215 VERSUS Commissioner of Central Goods and Services Tax : Respondent Bolpur Commissionerate, Nanoor Chandidas Road, Sian, Bolpur, District: Birbhum, West Bengal - 731 204 APPEARANCE:

Shri K.S. Chakraborty, Consultant, For the Appellant(s)

Shri B.K. Singh, Authorized Representative, For the Respondent CORAM:

HON’BLE SHRI ASHOK JINDAL, MEMBER (JUDICIAL)

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

FINAL ORDER NOs. 75255-75256 / 2026 DATE OF HEARING: 28.01.2026 DATE OF DECISION: 18.02.2026 ORDER: [PER SHRI K. ANPAZHAKAN]

M/s. Haldia Steels Ltd (Unit-II), having their factory at Raturia Industrial Area, Angadpur, Durgapur, West Bengal 713215, (hereinafter referred to as the “appellant/company”) are engaged in the manufacture of excisable Sponge Iron & Billets etc. falling under Chapter Sub-heading Nos. 72031000 and 72071920. The appellant-company is duly registered with the Central excise Department, having Registration No. ECC No. AACH6712KXM002.

1.1. The case against the appellants has been registered on the basis of the documents recovered and statements recorded by the officers of the Directorate General of Central Excise Intelligence, New Delhi (“DGCEI” for short), in respect of one M/s Shree Parasnath Re-Rolling Mills Ltd. (hereinafter referred to as “M/s SPRML”). Summons were issued to various concerned persons and their statements were also recorded.

1.2. During the course of investigation, a statement was recorded from Shri Satpal Bansal, Director of the appellant-company (the appellant no. 2 herein) by the Superintendent of C.E., Anti-Evasion, Durgapur Commissionerate on 06.05.2016. In the statement, the Director of the appellant-company / appellant no. 2 did not agree with the allegations of clandestine removal made against the appellant-company.

1.3. The documents relied upon by the officers against the appellant company were a bunch of loose papers seized from M/s. SPRML and the statements recorded during the course of investigation against M/s SPRML. The appellants contended that the documents relied upon against them have no statutory validity and were not supported by any corroborative evidence. Thus, the appellants did not agree with the allegations of clandestine removal and the demand of central excise duty worked out by the Revenue on the basis of data available in documents seized from the said M/s SPRML. During the course of investigation against the appellants, statement was also recorded from Shri R.K. Singh, General Manager (F&A) of the appellant-company.

1.4. On the basis of the aforesaid statements of the Shri Satpal Bansal, Director, Shri. R.K. Singh, General Manager and the purported findings of the DGCEI, New Delhi about unaccounted purchase of raw materials by M/s SPRML reportedly detected from the said company's private records, a Show Cause Notice was issued to the appellants demanding Central Excise duty of Rs.3,82,88,517/- inclu