No Excise Duty Exemption Without Direct Export: Supreme Court Dismisses Appeal [Read Judgement]
Both the Tribunal and High Court had found that the company merely sold goods domestically to another entity, not exported them under statutory procedure.
The Supreme Court has ruled that an excise duty exemption cannot be claimed without a direct export, dismissing the appeal filed by Natural Lights Pvt. Ltd. against the Rajasthan High Court’s order.
The dispute arose from an order of theCustoms, Excise and Service Tax Appellate Tribunal (CESTAT), New Delhi, dated March 4, 2025. The Tribunal had held that Natural Lights Pvt. Ltd. was not entitled to duty exemption since the goods were sold to M/s Central Electronics Ltd. (CEL) rather than directly exported under ARE-I forms.
The counsel for the appellant in the high court judgment stated that the goods manufactured by the appellant were handed over to a company, namely, Central Electronic Ltd., which ultimately exported the goods; therefore, the claim of the appellant that the goods were exported cannot be said to be wrongful.
The counsel also submits that the appellant had also placed documents to show that the concerned company, M/s. CEL exported the goods, and the said documents reflecting the same were required to be considered by the Tribunal.
The Rajasthan High Court, in its judgment dated November 12, 2025, agreed with the Tribunal, noting that the appellant had only supplied goods to CEL, which in turn allegedly passed them on to M/s Angelique International Ltd. for export to Mozambique.
After considering the matter, the Supreme Court bench comprising Justice Manoj Misra and Justice Manmohan refused to interfere under Article 136 of the Constitution, holding that no substantial question of law was raised.
The court observed that “We do not find a good ground to interfere with the impugned order/judgment in exercise of our jurisdiction under Article 136 of the Constitution of India. Accordingly, the special leave petition stands dismissed.”
Accordingly, the petition was disposed of
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