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GUJARAT HIGH COURT
THE PRINCIPAL COMMISSIONER, CGST AND CENTRAL EXCISE – Appellant
Versus
M/S SHAH FOILS LIMITED – Respondent


ORAL ORDER

(PER : HONOURABLE MR. JUSTICE BHARGAV D. KARIA)

1. Mr.Nirzar Desai, learned advocate for the appellant has tendered Draft Amendment. The same is allowed in terms of the Draft. To be carried out forthwith.

2. These Tax Appeals under Section 260A of the Income Act, 1961 (for short the “Act”) at the instance of Revenue and are directed against the common impugned Order No.A/10120-10125/2019 dated 18.01.2019 passed by the Customs, Excise & Service Tax Appellate Tribunal, Western Zonal Bench, Ahmedabad in Appeal Nos.E/10151/2018, E/11436/2018 and E/11433/2018.

3. As the Tribunal has passed the common order in case of the the appellant-Company and its two Directors, all three appeals are disposed of by this common order.

4. The following substantial questions of law are proposed by the Revenue:-

“2(a) Whether in the facts and circumstances of the case, the Hon'ble Custom, Central Excise and Service Tax Appellate Tribunal, Western Zonal Bench, Ahmedabad has committed an error in giving perverse findings on facts which are without any evidence and contrary to the material evidences available on record?

(b) Whether in the facts and circumstances of the case, the Hon'ble Custom, Central

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