Commissioner Of Central Excise,Bolpur vs M/S.Ratan Melting & Wire Industries

The Supreme Court clarified the interpretation of paragraph 11 of Dhiren Chemical Industries case, emphasizing that circulars issued by the Central Board of Excise and Customs cannot override the law laid down by the Court, as per Article 141 of the Constitution. The Court held that while benefits granted under exemption notifications should not be reopened, this does not allow courts or tribunals to prioritize Board circulars over Supreme Court judgments in ongoing disputes. The decision in Collector of Central Excise, Patna v. Usha Martin Industries was explicitly overruled by the Constitution Bench in Dhiren Chemical's case.