Natural Lights Pvt. Ltd. Vs Principal Commissioner (Supreme Court of India)
The Supreme Court dismissed the Special Leave Petition, declining to interfere with the Rajasthan High Court judgment under Article 136 of the Constitution, thereby upholding the denial of excise duty exemption. The High Court had examined whether the appellant was entitled to exemption on the ground that the goods manufactured by it were ultimately exported through intermediary entities. The appellant contended that goods supplied to another company were eventually exported and supported this claim with documents. However, the High Court noted that the transaction involved multiple parties, where an export order was routed through different entities before reaching the appellant, which manufactured and supplied the goods to an intermediary company.
The Tribunal had concluded, based on examination of records, that the appellant did not directly export the goods under ARE-I but instead sold them to the intermediary. Consequently, the appellant was not eligible for excise duty exemption meant for exports. The High Court found these findings to be factual and based on evidence, and held that no substantial question of law arose. Accordingly, it dismissed the appeal. The Supreme Court, by refusing to interfere, affirmed that exemption from excise duty cannot be claimed where goods are not directly exported by the manufacturer but are instead sold to another entity for further export.
