(1.) HEARD both sides.
(2.) THE learned SDR appearing for the Department states that the Department's appeal is in respect of reduction in the penalty by the lower appellate authority as well as in respect of not confirming the additional duty demand for the period prior to 19 -4 -2006. As rightly pointed out by the learned counsel for the respondents, in none of the grounds of appeal from para A to E and similar paragraphs in the Order -in -Revision passed by the Committee of Commissioners, there is any challenge to non -confirmation of additional duty demand for the period prior to 19 -4 -2006. As such, the Tribunal cannot go into this question in the absence of any ground taken in this regard in the Department's appeal.