(1.) IN this appeal at the instance of the assessee challenging the order passed by the Commissioner (Appeals), the main ground raised is violation of principles of natural justice. The appellant has also raised contentions on merits. The relevant facts are as follows:
(2.) THE period involved is from 1.4.94 to 31.8.97. No show cause notice was issued. Under the order in original dated 28.2.2001 and amount of Rs. 21,97,26,743/ - is confirmed against the appellant. Appeal filed was dismissed by the Commissioner (Appeals) by order dated 31.3.2003.
(3.) THE appellant is engaged in the manufacture of cotton and man -made yarn. 15% of the yarn produced is sold ex -factory. 38% to consignment agents for onward sale. 47% is consumed captively in the manufacture of fabrics. It is claimed that fabrics are sold by the appellant directly from factory gate.