ALO Law Office- IDT Tax I Arbitration I Litigation
Date: 03.10.2025
CESTAT Bangalore Clarifies MRP-Based Assessment for Industrial Goods
This Article has been written by Shri Ravi Shekhar Jha, Advocate based in New Delhi. The views expressed are based on his interpretation of the law. He can be reached at his email id intelconsul@gmail.com or on his Mobile +91-9999005379.
In a significant ruling, the Customs, Excise & Service Tax Appellate Tribunal (CESTAT), Bangalore, has set aside the demand for differential customs duty of Rs. โ 2.72 crore against M/s. โ BEML Ltd., a leading manufacturer of industrial equipment. โ The case, which revolved around the applicability of MRP-based assessment under Section 4A of the Central Excise Act, 1944, highlights the nuanced interpretation of legal provisions governing industrial and retail sales. โ
Background of the Case
BEML Ltd., engaged in manufacturing heavy industrial equipment such as dumpers, motor graders, and Tatra trucks, imports spare parts and components for these products. โ These imports are distributed to industrial consumers either directly or through their marketing network. โ The dispute arose when the Customs Department alleged that BEML failed to discharge the applicable duty under Section 4A, which mandates MRP-based assessment for retail packages. โ A demand notice was issued for the recovery of Rs. โ 2.72 crore for the period April 2010 to November 2011, along with interest and penalties.
Source: CESTAT Bangalore
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