CUSTOMS, EXCISE AND SERVICE TAX APPELLATE TRIBUNAL
CHANDIGARH
REGIONAL BENCH - COURT NO. I
E/60186/2024 & 08 others
Excise Appeal No. 60186 of 2024
M/s Vimal Alloys Pvt. Ltd.
Village Sounti, Amloh Road, Mandi,
Fatehgarh Sahib, Punjab-141441
……Appellant
VERSUS
Commissioner of Central Excise
and Service Tax, Ludhiana
GST Bhawan, F-Block, Rishi Nagar,
Ludhiana, Punjab-141001
……Respondent
WITH
2. Excise Appeal no. 60187 of 2024 [ M/S Hansco Iron & Steel Pvt. Ltd.]
3. Excise Appeal no. 60189 of 2024 [ Ashok Aggarwal]
4. Excise appeal no. 60190 of 2024 [ M/s Bhawani Casting Pvt. Ltd.]
5. Excise Appeal no. 60201 of 2024 [ M/s Unique Ispat Pvt. Ltd.]
6. Excise Appeal no. 60379 of 2024 [ Rajiv Kumar Garg]
7. Excise Appeal no. 60411 of 2024 [ M/s Shree Ganesh Alloys]
8. Excise Appeal no. 60413 of 2024 [ M/s Kuber Inds. (India) Mgg.]
9. Excise Appeal no. 60742 of 2024 [ M/S Bassi Steels Limited]
APPEARANCE:
Shri Naveen Bindal and Shri Bharat Jain, Advocates for the Appellant
Shri S.K. Meena, Authorized Representative for the Respondent
CORAM: HON’BLE MR. S. S. GARG, MEMBER (JUDICIAL)
FINAL ORDER NO. 60333-60341/2026
DATE OF HEARING: 22.04.2026
DATE OF DECISION: 29.04.2026
These 09 appeals are directed against the different impugned orders passed by the Commissioner (Appeals) whereby the Commissioner (Appeals) has rejected the appeals of the appellants and confirmed the Order-in-Original. All these are arising out of the same investigation and allegations against the appellants are also identical that they have been taking CENVAT credit against the forged invoices without getting the material. Since the relief in all the appeals sought by all the appellants is identical therefore it would be appropriate to take up all the appeals together for the purpose of discussion and disposal. The details of all the appeals are given herein below:
| Sr. No. | Appeal No. | Party name | Period | Amount of Central Excise Duty Involved | Amount of Penalty Imposed | Impugned order no. and date |
|---|---|---|---|---|---|---|
| 1. | E/60186/2014 | M/s Vimal Alloys Pvt. Ltd | Dec’2016 | 25,621 | 25,621 | LUD-EXCUS-001-APP-31-32-2024 dated 01.02.2024 |
| 2. | E/60187/2024 | M/S Hansco Iron & Steel Pvt Ltd | Dec’2015 | 1,88,720 | 1,88,720 | LUD-EXCUS-001-APP-29-30-2024 dated 01.02.2024 |
| 3 | E/60189/2024 | Ashok Aggarwal | Dec’2015 | - | 3,55,381 | LUD-EXCUS-001-APP-45-46-2024 dated 08.02.2024 |
| 4 | E/60190/2024 | M/S Bhawani Casting Pvt Ltd, | Dec’2015 | 3,55,381 | 3,55,381 | LUD-EXCUS-001-APP-45-46-2024 dated 08.02.2024 |
| 5 | E/60201/2024 | M/S Unique Ispat Pvt Ltd | Dec’2015 | - | 3,95,783/- | LUD-EXCUS-001-APP-37-38-2024 dated 05.02.2024 |
| 6 | E/60379/2024 | Rajiv Kumar Garg | Dec’2015 | - | 3,95,783 | LUD-EXCUS-001-APP-37-38-2024 dated 05.02.2024 |
| 7 | E/60411/2024 | M/S Shree Ganesh Alloys | Dec’2015 | 2,07,063 | 2,07,063 | LUD-EXCUS-001-APP-22-23-2024 dated 05.02.2024 |
| 8 | E/60413/2024 | M/S Kuber Inds. (India), Mgg | Dec’2015 | - | 24,03,486 | LUD-EXCUS-001-APP-28-2024 dated 01.02.2024 |
| 9 | E/60742/2024 | M/s Bassi Steels Limited | Feb to March 2017 | 6,89,865 | 6,89,865 | LUD-EXCUS-001-APP-389-2024 dated 04.10.2024 |
2. Briefly, the facts of the present case are that acting on the information that few manufacturing units located in Delhi were engaged in fraudulently passing of CENVAT credit of duty to various furnace units of Punjab, investigation was initiated by Directorate General of GST Intelligence (DGGI). DGGI conducted investigation in respect of four manufacturing units viz. Citizen Steel Forge, Bhartam Industries, Glico Industries and Universal Industries all located in Delhi. Simultaneous search was conducted at the residential premises of Sh. Rohit Garg at Mandi Gobindgarh, Sh. Amit Goyal at Mandi Gobindgarh and Sh. Robin Jain at Malerkotla on 08.02.2018.
2.1. During the search, various incriminating documents were resumed and statements of Sh. Rohit Garg and Sh. Amit Goyal was recorded. In follow up action, statement of Sh. Ramanpreet Singh Waraich, Proprietor of M/s Universal Industries and Sh. Rishi Pal, land owner of the property shown as M/s Universal Industries was also recorded and further statement of various other persons such as Sh. Ravinder Bajaj, accountant of Kansal Sons Steels Ltd., Mandi Gobindgarh, Sh. Vipin Kumar Kansal, Smt. Pooja Kansal was also recorded.
2.2. Thereafter, on the basis of various statements and the document, DGGI has formed an opinion that above mentioned four units was not having any manufacturing facility, had no purchases, had no electricity consumption and therefore, did not actually manufactured and sold the goods to various dealers. Thereafter, show cause notices were issued to various appellants and after following the due process, both the authorities below have confirmed the demand as stated in the table above. Aggrieved by the said order, the appellants have filed these appeals.
3. Heard both sides and perused the material on record.
4. Learned Counsel for the appellant submits that the impugned orders are not sustainable in law as the same has been passed without properly appreciating the facts, the law and the binding judicial precedents. He further submits that during the course of investigation, statements of various persons from whom the appellants have made purchases have been recorded but cross
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