FINAL ORDER NO.60388-60389/2026

DATE OF HEARING: 19.03.2026

DATE OF DECISION: 02.06.2026

P. ANJANI KUMAR:

1. M/s ACC Ltd (Appeal No. E/60524/2025) and Ambuja Cements Ltd (Appeal No. E/60906/2025) assail the impugned orders dated 29-4-2025, passed by the Commissioner (Appeals), CGST, Chandigarh, upholding the Order-in-Original dated 26-12-2024 and 27-11-2024 respectively, passed by the Assistant Commissioner, CGST Mandi Division, Himachal Pradesh, wherein the amount of refund granted to the appellants, in pursuit of Tribunal’s Final Order No.60395-60396/2024 dated 1-7-2024, was reduced to the extent of Rs. 55,00,39,624 and 12,81,28,016 respectively, on account of Cenvat Credit availed on Clinker manufactured and used by them captively. Factual matrix of both the cases being identical and being dealt a common impugned order, both appeals were heard together and are being taken up together.

2. Both the Appellants’ factories are located in Himachal Pradesh and were engaged in the manufacture of Cement; the appellants availed exemption from Central Excise duty under Notification no.50/2003-CE dated 20th June 2003; the Appellants also manufactured Clinker, part of which was cleared out