9911796707
TMI Blog2017 (7) TMI 1027X X X X Extracts X X X X X X X X Extracts X X X X ..... Gupta had admitted the case of clandestine removal or under valuation by RPIL. There is no evidence produced to establish that there has been flow back of any funds to establish under valuation and therefore under valuation is also not established in the present case. Therefore, while setting aside the demand of duty raised on account of clandestine removal or under valuation, we also set aside the impugned order. As regard confiscation, we found that the Panchnama does not refer to any method of verification of stock, which was otherwise not possible in such a short span of time. Further, the show cause notice referred to statements of Shri Dwarika Dhish Sharma and Shri S.G. Gupta on the spot in this regard whereas no such statement was produced or found on record (RUD). The goods were very well in the factory and not even a single roll was found kept outside or in concealed manner or loaded on vehicle for removal without duty. Mere holding of the explanation as afterthought was not sufficient to confiscate the goods. As regard demand of duty on account of shortage during stock verification, we set aside the same also on the basis of observation made above. We also set asid ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 70229/2017 E/MISC/70120/2017 E/70230/2017 E/MISC/70121/2017 E/70231/2017 E/MISC/70122/2017 E/70232/2017 E/MISC/70123/2017 E/70233/2017 E/MISC/70124/2017 E/70234/2017 E/MISC/70125/2017 E/70235/2017 E/MISC/70126/2017 E/70236/2017 E/MISC/70127/2017 E/70237/2017 E/MISC/70128/2017 E/70238/2017 E/MISC/70129/2017 E/70239/2017 E/MISC/70130/2017 E/70240/2017 E/MISC/70131/2017 E/70241/2017 E/70127/2017 S G Gupta, New Empire Plastic, A K International, Sgm Paper Product, Kumar Sons Industries, Guideman Tape Industries, Wadhumal Sons, Eastern Rainwear, Zeeshan Enterprises, Jayanti Cottex, Batra Rexine Co, Siddharth Brothers, J R Bhatia Co, Mobil India Marketing Co, Modern Enterprises, Ram Bhagat Ashok Kumar, J S Seat Maker, Bajaj Plastic, Mayur Plastic, Rosla Waterproof Works, Popular Stores Mumbai, Brahmputra Enterprises, Techno Trade, Nidhi Elastomer India Pvt Ltd, Agarwal Cloth Stores, Gulshan Agencies, Chowdhary International Limited, Raja Plastic House, Chowdhary Waterproof Works, Mukesh Raj Gobind Lal, P J International, Shakti Enterprises Versus CCE ST Noida ORDER Per : Anil Choudhary These appeals are arising out of Order-in-Original No. 46-47/COMMSSIONE ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... PVC Laminated Sheeting (Hitech) -1.30 mm 23560 30080 6520 120.17 783508 5. PVC Laminated Sheeting (Hitech) -1.80 mm 210 8634 8424 180 1516320 6. PVC Flooring (Tiles) 2.00 mm 1064.9 1334.21 269.31 30 8079 7. PVC Flooring (Insulating mat) 2.00 mm 1007 1733 726 250 181500 Total 3826266 Raw Material S. N. ITEM QTY. PHYSICALLY VERIFIED (IN KGS) TOTAL QTY. AS PER RECORD (IN KGS) DIFFERENCE (IN KGS) VALUE (IN RS.) 1. PVC Resin 708575 709332 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cabin of Shri S.G. Gupta. Thereafter, the officers opened the briefcase in the presence of witnesses and Shri Gupta and Shri Sharma and recovered two private ledgers and two writing pads and took the photocopies of the same in the adjoining room in the presence of Panch witness. Apart from the above, one file containing some miscellaneous papers was also recovered from the same room. These two ledgers and the two writing pads were again placed in the briefcase after getting signatures of the panchas on the first and in the last page of photocopies and the briefcase was sealed. For further investigation, some other records were also segregated by the officers from the gate of the factory, quality control section, dispatch section, excise section and the store section which were resumed as per the Panchnama. The stock taking of Cenvatable raw material and finished goods was also undertaken by the officers in the presence of representatives of RPIL, details of which was incorporated in Annexure A, B C of the Panchnama. As a result of the physical verification, the search team detected the excess stock of finished goods valued at ₹ 1,13,97,502/- involving duty to the tune of &# ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... then checked with the same number of statutory invoices issued by the RPIL. It was noticed that invoices mentioned in the private ledger do not match, in terms of value or date with the statutory invoices. As mentioned above, these private ledgers have only date and debit entries for the cash which is the value of goods. The largest account available in both the ledger was of Bajaj Plastic. However, in statutory record, there was no invoice found issued in the name of M/s Bajaj Plastic. The statutory invoices were found issued in some other names like M/s Matting House, Delhi, M/s King Decor, Hyderabad, M/s Dossa Harjee, Mumbai, M/s R.K. Enterprises, New Delhi, M/s Amar Udyog, New Delhi, M/s JRD International, Rohini, Delhi, M/s Vicky Enterprises, Daryaganj, Delhi etc. It was also noticed that value shown in the statutory invoices was much below the value shown in the debit column of private ledgers. Preliminary scrutiny of writing pads revealed that Writing Pad 92 pertain to period 2010-11 2011-12. In some entries, printing charges were also separately charged. However, name of the consignees to whom the goods were consigned, were not mentioned. Further, no cash or cheque entri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... adar Bazar, Delhi, 7. Panchnamas were drawn at the aforementioned places. During the course of search, few records, computer hard disks and a computer was resumed from the factory situated at Shikandrabad and office premises of RPIL located at Vaishali Ghaziabad, U.P. Few records were also resumed from M/s Bajaj Plastics, M/s P.J. International and M/s Mulak Raj Govind Lal. M/s Vicky Enterprises, was found closed and non operational by the visiting officers. As regards M/s J.R.D. International, the owner of the premises informed that they have left the premises 4-5 years back. In rest of the premises nothing incriminating was found. Statements of officers and persons were recorded under Section 14 of Central Excise Act, 1944, as under:- (a) Shri Dwarika Dish Sharma, Store Manager and Authorised Signatory of RPIL, Shikandrabad, (b) Shri S.G. Gupta, Executive Director of RPIL, Shikandrabad, (c) Shri Puran Dass Taneja, the then Commercial Manager now Consultant of RPIL, Kailash Colony, New Delhi, (d) Shri Manoj Agarwal, the then AGM (Accounts) now GM (Accounts), (e) Shri Satish Kumar Bajaj, Partner of Bajaj Plastic, Nabi Karim, Delhi, (f) Shri Nit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rs/kachcha records a large number of sales were booked in their name. For example, the bill numbers shown in M/s Bajaj Plastics accounts, when checked with the same number of statutory invoices, it was found that the invoices were issued in different buyers, namely-M/s Matting House, Delhi, M/s King Decor Hyderabad, M/s Dossa Harjee, Mumbai, etc. Further the value shown in the statutory invoices was much below the value shown in private ledger/kachcha records. For example, at page 61 of private ledger - 91, in Bajaj Plastics account, on 28.10.2011, a Bill No. 2511 is entered for an amount of ₹ 2,22,683/-. When this entry was checked with statutory invoice No. 2511 dated 28.10.2011, it was found that statutory invoice was issued in the name of M/s JRD International, Rohini, New Delhi for ₹ 8,556.08/- only. It further appeared that the statutory invoice had been manipulated and issued for a value much below the actual value. It further appeared that the goods were removed clandestinely over and above the invoiced quantity and payments received in terms of cash against such clandestine removal, were accounted for in these ledgers. The fact that these dealers were placing o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... were also shown separately. However, names of the consignees to whom the goods were consigned, were not mentioned. Further, no cash or cheque entries were available in this pad. However, all the bills shown in this pad were also figuring in the private ledger 90 and 91 in PJs account. It appeared that all the transaction shown in this pad have been transferred in private ledger 90 and 91. Thus, it appears that on comparison of bill number mentioned in Kachcha records with the statutory invoices of same number issued by RPIL, it was found that some of the buyers, in whose name invoice were issued were dummy or bogus buyers. The said dummy buyers were not actually purchasing goods. The invoices issued in the name of said dummy buyers were used for transportation of clandestine goods from the factory to actual buyers place. For example, during visit on 5th February, 2013, it was found that M/s JRD International was lying closed at the given address (as per list provided by Shri S.G. Gupta during his statement dated 12th February, 2013 and as mentioned in invoices issued by the appellant RPIL) for last 4-5 years. The owner of the premises, herself informed during the visit of the Cent ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Works an invoice no. 3559 against dated 28 January, 2012 is mentioned. On scrutiny, it was found that statutory invoice no. 3559 dated 21 December, 2011 was issued in the name of M/s Indian Oil Corporation Ltd. Similarly invoice no. 3624 is written against dated 28 January, 2012 at page no. 162 of private ledger 90 in the account of Chaudhary Water Works. It was found as per statutory invoice no. 3624 dated 26 December, 2011 was issued in the name of M/s Indian Oil Corporation Ltd. Delhi Jaipur Highway. Several entries were found during scrutiny of private ledger vis-a-vis statutory invoice. Accordingly it appeared, appellant RPIL was indulging in undervaluing their goods to evade the Central Excise Duty. The cash entries shown as receipt in the writing pads also substantiate that the RPIL was collecting the amount in cash. It was further, the case of Department, Shri S.G. Gupta in his statement dated 18 March, 2013 has already accepted that the cash shown in the private ledger and writing pad was received against sale proceeds and Shri S.G. Gupta has further stated in his statement dated 10 April, 2013 that some time buyers want to purchase goods on less invoice price. In such typ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... being private ledgers and writing pads from Shri S.G. Gupta, party-wise detailed charts have been prepared by Revenue to work out the duty liability. The said charts have been summarised in Annexure B, C D to the SCN. Since entry in the writing pad 92 were also reflecting in Ledger 90 and 91 in the account M/s PJ and therefore, the same were not considered for calculation of duty liability. On the basis of these B, C, D charts, a final duty liability chart was prepared and annexed to the SCN marked as Annexure- E and accordingly, it appeared to Revenue that RPIL was liable to pay duty amounting ₹ 4,05,79,200/- and further liable to pay ₹ 4,72,926/- on the shortage of finished goods detected and ₹ 42,904/- on shortage of raw material detected. It further appeared that RPIL did not maintain proper accounts of raw material as well as finished goods in order to suppress their production and to clear the goods clandestinely without payment of duty and in violation of the Rules particularly Rule 4, 6, 8, 10 and 11, CER 2002, and it also appeared that the Executive Director Shri S.G. Gupta was actively involved in the suppression of production and clandestine removal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ein, and Premier Polyfilm Limited. 11.2 The learned Commissioner took note of the fact that appellant RPIL approached Settlement Commission for settlement of the case but their application was rejected by the Settlement Commission by its order dated 02 June, 2015. Learned Commissioner have quoted para 32 to 37, 43 and 44 from the order of Settlement Commission. He further observed that the Settlement Commission rejected the application of RPIL and sent the case to Adjudicating Authority to adjudicate the case. 11.3 It was observed that during the visit on 13 April, 2012, two private ledgers and two writing pads-kachcha records were resumed from the office cabin of Shri S.G. Gupta Executive Director of appellant company. These were resumed by the Sr. No. 90 to 93 of Annexure-D to the Panchnama. The said documents were found to be in the form of ledger 90 and 91 and the Sr. No. 92 and 93 were writing pads. It is further observed that in view of Section 36 A of the Act the said private records were to be treated as records of RPIL, said section is reproduced as under- Section 36-Where any document is produced by any person or has been seized from the custody or control of a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ly they were issuing their invoices in the name of bogus/fictitious/dummy buyers only to facilitate them. Learned Commissioner had made reference in the show cause notice regarding the accounting of the invoices in the name of another party and issue of invoices in the name of another. It was further observed that as per the private records/ledger substantial supplies were to Bajaj Plastic and Mulak Raj Govind Lal. But it is very surprising to see that no invoice has been issued in the name of these two traders during the period 2010-11 and 2011-12. Further the person(s) from Bajaj Plastic and Mulak Raj Govind Lal in their statements stated that they have no idea about such entries mentioned in the private record maintained by Shri S.G. Gupta, which also shows that these buyers were receiving the goods, were paying the differential payment in cash. Similar practice have been done in the case of M/s Mobile India Marketing Company, Mallapuram and M/s J.S. Seat, Delhi. The learned Commissioner further observed that some of the entries of the private ledger, where receipt was shown by cheques/RTGS/DD without these matching with the bank statement of RPIL during the relevant period, (s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion of clandestine production has not been supported by any other corroborative evidences, Learned Commissioner observed that the evidences on record are corroborated. He further observed that the statement of Shri S.G. Gupta, who was the Executive Director, is confirmatory in nature as he agreed in his statement that the said private records were maintained by him only. Shri Gupta has also stated that the cash shown in the private/kachcha records were sale proceeds of RPIL and were not accounted in the books of accounts of the company. Thus, when the department was having more than sufficient corroborative evidences, there was no need to go into inquiry regarding use of electricity/fuel and manpower, etc. Further, the contention of the appellant is that the alleged private records which were resumed from Shri S.G. Gupta, were his private and personal records and RPIL has no concern, is not acceptable in view of the statutory invoices were having lesser value. It is not possible that any buyer will purchase goods on higher value without invoice. It is further observed by the learned Commissioner that the stand is contradictory in nature. On one hand they are saying that some record ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the same was done by the officers to type in English. There are some mistakes in that translation. 16. In reply to the cross examination, by Shri Ashish Kumar Shukla, advocate, who appeared on behalf of 11 co-noticees, on asking questions, Shri S.G. Gupta had replied that he had rendered his statement/reply in Hindi and translation of the same by the Excise officers, was typed in English and there are some mistakes in the translation due to which he does not fully agree with the statement. The learned Commissioner on this contention, further observed that the said contention tried to divert the issue by submitting that the entries found recorded in diaries were containing the detail of RPIL and M/s Premier Polyfilm Ltd. It is further observed that Shri Gupta never said this aspect to the department before. This shows that this aspect is only afterthought to divert the issue from main subject. It is further observed that person who turned up for cross examination of Shri. S.G. Gupta were mostly those persons who had actively participated in the whole gamut. These persons have mostly preferred to ask same questions. Thus the purpose of cross examination had reduced to the extent ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rther observing that in none of the statements/averments by the appellant company or its directors and personnel, they have been able to explain the unaccounted cheques, which seems to make it clear that the evasion of duty through clandestine removals was a well organized operation of the appellant and they have also not objected to the accuracy of the stock taking at no point of time, and accordingly, both the show cause notices were adjudicated by the common Order-in-Original and the proposed demand confirmed and also penalty was imposed. Confiscation were also ordered with regard to the finished goods valued at ₹ 1,13,97,502/- and raw material valued at ₹ 54,146/- under Rule 25 of CER, 2002, being found in excess at the time of inspection with further option to redeem on payment of redemption fine of ₹ 28,62,912/- in lieu of confiscation and further order to appropriate the redemption fine from the bank guarantee of equal amount furnished earlier. Further penalty of ₹ 14,14,308/- was imposed under Rule 25 read with Section 11AC of the Central Excise Act, 1994. Other penalty, under provisions of Rule 26 was imposed on 33 co-noticees as given below, who w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mpire Plastic, Bombay-3 0.69 Lakhs 50,000/- (Fifty Thousand) 13. 16 M/s SGM Paper Products, Gurgoan (Haryana) 0.56 Lakhs 50,000/- (Fifty Thousand) 14. 17 M/s A K International, Kolkata 0.32 Lakhs 25,000/- (Twenty Five Thousand) 15. 18 M/s Guideman Tape Industries, Delhi 1.74 Lakhs 1,00,000/- (One Lakhs) 16. 19 M/s Rosla Water Works, Kolkata 1.45 Lakhs 1,00,000/- (One Lakh) 17. 20 M/s J.R. Bhatia Company, Delhi 19.73 Lakhs 4,00,000/- (Four Lakhs) 18. 21 M/s Gulshan Agencies, Delhi 8.44 Lakhs 2,50,000/- (Two Lakhs Fifty Thousand) 19. 22 M/s Ku ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 36 M/s Chowdhary International, Kolkata 0.21 Lakhs 20,000/-(Twenty Thousand) 17. Being aggrieved, the appellants have filed these appeals. The learned counsel appearing for the appellant company RPIL and its director Shri Arvind Goenka and other appellants urges that there are material defects in the order of the learned Commissioner and thus the order is perverse both on facts and in law and it is fit to be set aside. 18. Referring to the statement of Shri S.G. Gupta dated 12 February, 2013, attention was drawn towards certain questions-answers which are reproduced below:- Que.17Photocopy of said ledger and writing pads shown, please explain the purpose of these ledgers and writing pads and the person responsible to maintain these books. It was answered as:- Ans: I have seen the said ledger and writing pads. Yes, these books were resumed from my cabin on 13/14 April, 2012. These records are my private records, which were maintained by me. I had business relation with some of the dealers of PVC Sheeting, other than factory (RPIL). These records were being maintained to settle or to pay their ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... entries, as informed by the concerned party regarding sale. The names of dealer along with addresses, as per private ledger/writing pads, have already been submitted to you on 18 February, 2013. Q.10. Ongoing through the said books, it is observed that you were indulged in clandestine removal of goods and the said private ledgers were being maintained to account for the clandestine sale proceeds. Please explain. Ans: The goods cleared from the factory were duty paid and proper invoices were issued. The cash entries shown in the ledger are for the goods cleared other than the invoices. Further referring to the statement of Shri Arvind Goenka Director of RPIL recorded on 20 March, 2013, learned counsel drawn the attention to that, Q.10. Please see the kachcha records i.e. private ledgers(2 Nos.) and writing pads(2 Nos.) recovered during search on 13/14 April, 2013 from the cabin of Shri S.G. Gupta, Executive Director. Shri Gupta in his statement admitted that the said records are private records and were being maintained by him. The said records pertain to clandestine removal of goods made from factory. Do you agree with his admittance. Ans: I have seen the said priva ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Shri Arvind Goenka. The details of invoice/transaction issued from both the companies will match the records of both companies. The details of some buyers and value may differ. Thus in the nutshell the learned Commissioner and investigation had erred in considering the said private records and the entries and transactions contained therein as related to the appellant RPIL only. The learned counsel further states that it is evident from the findings of the learned Commissioner that he has drawn erroneous conclusions based on the statement of Shri S.G. Gupta as well as the transactions contained in his private records. The learned counsel further points out that there is no bifurcation and or classification or investigation regarding the contents of those private records in question. As such the investigation was misconducted and have drawn illogical conclusions and the same have been adopted by the learned Commissioner in his finding in confirming the duty along with the penalty and accordingly the impugned order is fit to be set aside. 20. The learned counsel further points out that the so called statements recorded on the date of the search, of Shri Dwarika Dish Sharma, Store M ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in dealing with the issue of evidentiary value of material produced before Settlement Commission, when proceedings before Settlement Commission failed, the substantial question before Hon ble Gujarat High Court was-whether in the facts and circumstances of the case the Tribunal was justified in the eyes of law in holding that the statements of Shri Babubhai S. Patel and Shri Rajeshbhai A. Patel were retracted and cannot be relied upon, though their statements dated 23 July, 2004 and 18 May, 2005 respectively were never retracted, and also corroborated by other independent piece of evidence gathered during the investigation, regarding the clandestine clearance of the goods by the respondent-assessee and as to whether in the facts and circumstances, the Tribunal is justified in law in holding that the Revenue has failed to establish the clandestine clearance of the goods by the respondent-assessee in spite of it being admitted in its Settlement Application under Section 32E(1) of the Central Excise Act, 1944, before the learned Settlement Commission. The Hon ble High Court observed that the contention of the Revenue that the respondent herein specifically admitted the charges as per ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y learned Commissioner on the submissions made by the appellant RPIL before Settlement Commission, have vitiated the impugned order, as held in the ruling of Hon ble High Court of Gujarat in the case of Commissioner v/s Maruti Fabrics (supra). 25. The learned counsel have further urged that it is settled proposition of law that for establishing clandestine removal and/or manufacture, conclusion cannot be drawn on stray piece of evidence. The department is also required to take into consideration other corroborative evidences like procurement or source of raw material, production, capacity, availability of electricity, availability of labour, removal of goods including the capacity of transportation required for procurement of raw materials and removal of the finished goods alleged to be removed in clandestine manner. It was also urged that all major raw material supplier being large scale manufacturer and that too outside the State of U.P., it was otherwise not possible to procure the same in a clandestine manner. Further for manufacture of final product, they require number of raw materials like resin, plasticizes, stabilizes, pigment etc. and no discrepancy in recording of sam ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bound to be substantial variation in the power consumption. The learned counsel heavily stressed upon the fact that when from the very beginning Shri S.G. Gupta had stated that his records pertained to RPIL PPL, which fact was repeatedly asserted before the Commissioner before whom details of invoices issued and cheque/C-forms received by PPL supported with bank statement of customers (co-appellants) of PPL were produced. 27. The counsel urged that the fact that private records of Shri S.G. Gupta had information of PPL also, was stated by him in his statement dated 12.03.2013 and again on 18.03.2013. The said fact was reaffirmed by many of the parties in their reply, some of whom filed affidavit also before the lower authority. However, still the Commissioner held such transactions as pertaining to RPIL. The learned counsel further points out that so far as the ruling of Apex Court in D. Bhoormull is relied upon by the learned Commissioner is concerned, the said ruling was under the Customs Act where provisions are different from the provision of Central Excise Act, 1944. Under the said Customs Act any person found with goods prima facie of foreign origin, is supposed to prov ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... submitted that there was no mention of any method to determine the stock of 4.05 lakhs sq. meter in 9100 rolls, weighing approx 633 MT, especially, when there were number of the sizes of rolls. 29. Accordingly, we have heard the rival contentions and in view of the contentions and evidence on record, noted hereinabove, we observe that the learned Commissioner has erred in his findings based on the submissions and admission made by the appellant-RPIL before Settlement Commission, which are wholly against Section 32 E(1) of the Act. The learned Commissioner has also erred in relying on the case made out by the investigation, in view of the glaring fact that Shri. S.G. Gupta has stated that the said private record contains entries relating to RPIL-appellant, Premier Polyfilm Ltd. and his personal affairs. No effort was made by investigation in segregating entries with respect to particular company and/or the appellant leading to erroneous conclusion by declaring all the transactions recorded in the said diary/private ledgers as attributable to appellant RPIL. Further, Shri. S.G. Gupta has categorically stated that no clearance have been made by RPIL without issuance of invoice. Fur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lso fail to understand as to why Department did not make enquiry against PPL in spite of having such information at the beginning of their investigation. Therefore, we hold that the department has miserably failed to make out case against the appellant. It is a well settled law that the charge of clandestine removal and under valuation being serious charge, the department is required to produce corroborative evidence, which the department has failed in the instant case. Accordingly, we allow all the appeals. The appellants shall be entitled for consequential benefit as per the law. 32. The learned counsel Shri Atul Gupta, who is appearing for Shri S.G. Gupta urges that in the first show cause notice there was proposal for confiscation of seized goods in which Shri. S.G. Gupta is not made a party, whereas in the second notice while proposing penalty under Rule 26, there is no proposal of confiscation of the seized goods on which duty have been demanded. 33. The learned counsel urges that the pleadings and or averments made in the two show cause notice cannot be clubbed for imposing penalty on the appellant Shri S.G. Gupta, who was not a party in the first show cause notice. Ac ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
