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Supreme Court of India 2019-05-08

M/S. STEEL AUTHORITY OF INDIA LTD. (UNIT BHILAI STEEL PLANT) ISPAT BHAWAN . THROUGH ITS SR. MANAGER (F AND A) vs COMMISSIONER OF CENTRAL EXCISE RAIPUR

Bench: 3 — Ranjan Gogoi, Uday Umesh Lalit, K.M. Joseph

In Brief

SAIL sold products to Indian Railways at prices subject to escalation clauses. Initially, excise duty was paid based on provisional prices. When prices were later escalated with retrospective effect, SAIL paid differential excise duty of Rs. 142.78 crores. The Revenue demanded interest under Section 11AB of the Central Excise Act from the date of original removal of goods. The Supreme Court held that interest is payable on such differential duty from the statutory due date prescribed in the rules (the 5th/6th of the following month) based on the month of removal, not from when the escalated price was agreed. The Court affirmed prior decisions in SKF India Ltd. and International Auto Ltd., holding that where prices are provisional and subject to escalation, the enhanced value applies retrospectively as the value at removal, and interest accrues accordingly.

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Excise Duty Interest on Delayed Payment Price Escalation Valuation Central Excise Act Provisional Assessment Retrospective Effect Self-Assessment

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