JUDGMENT : T.M. NADAF, J. 1. The revenue is before us challenging the final order in No. 20941-20942/2023 dated 15.09.2023 passed by Customs Excise and Service Tax Appellate Tribunal, Bangalore (‘CESTAT’ for short) in Appeal NO.ST-21349/2014. 2. The CESTAT by order impugned allowed the appeal setting aside the Order-in-original No.02/2014 passed by the Commissioner of Central Excise, Bangalore. 3. The brief outline of the facts leading to the filing of the appeal by the Revenue are as under. 4. The respondent is a manufacturer of parts and accessories of buses falling under Chapter 87 sub-heading 87082900 Central Excise Tariff Act, 1985 (‘CETA’ for short). During the verification of refunds claim dated 08.12.2011, the Revenue noticed that no duty was paid on the manufactured body built motor vehicles for the period May 2008 to July 2012. An investigation was probed into and on completion of the same, a show cause notice came to be issued against the respondent dated 08.06.2013, stating that there was a short fall of duty to the extent of Rs.67,46,70,752/- during the period stated supra; consequently, on adjudication, the demand was reduced to Rs.58,03,73,082/- with interest and penalty of equivalent amount imposed on the respondent and a sum of Rs.50,000/- on one of the Directors of the respondent/company, by the original order. 5. The respondent as well as the Director, feeling aggrieved by the original order were before CESTAT in Appeal No.E/21349 & 21350/2014. 6. The respondent before the Tribunal mainly argued that recovery sought is not permissible, as the respondent is entitled to avail the benefit of exemption under Sl.No.39 of the Notification No.6/2006-CE dated 01.03.2006 and Sl.No.276 of the Notification No.12/2012-CE dated 17.03.2012, on fulfillment of conditions prescribed in Sl.No.9/27. The respondent has asserted that it has fulfilled the following conditions: i) The motor vehicles should be designed for transport of more than six persons, excluding the driver, including station wagons; ii) The chassis manufacturer should have not have ownership on the chassis thus, effectively he should have sold the chassis to the person manufacturing the vehicles; iii) The manufacturer of the said vehicles should not have availed the Cenvat credit under the Cenvat Credit Rules, 2004; iv) The manufacturer of the said vehicles should not have manufactured the vehicles on account of the chassis manufacturer; and v) The manufacturer of such vehicles should not have manufactured the chassis by himself. 7. 7. The revenue opposed the contentions of the respondent on the count that since the ownership of chassis was continued to be vested with chassis manufacturer VIPL i.e., Volvo India Private Limited (‘VIPL’ for short) and by operation of Section 4 of the Central Excise Act, 1944, which states about the ‘related person’ found in both the undertakings, since both the companies are under the same management and control of common entity i.e., ‘AB Volvo’, Sweden. In the circumstances, the respondent is not entitled to claim any exemption under the Notification supra. 8. The Tribunal upon considering the rival contentions was of the opinion that, the consideration by the Commissioner in original order importing Section 4 of the Central Excise Act ('C.E. Act', for short) referring to the context of ‘related person’ in analyzing the conditions of the Notification is out of context, inasmuch as the question is not for determination of the value of the chassis sold. Further, the Tribunal opined that reliance placed under Section 4 of the C.E. Act to contend the meaning of interconnected undertaking in respect of respondent and VIPL, the manufacturer of chassis is also ruled out. 9. The Tribunal further held that the Clause 1.7 of Chassis Supply Agreement and Master Agreement dated 01.04.2001 providing license to manufacture entire range of products of ‘AB Volvo’ like trucks, buses, construction equipment etc. to M/s VIPL does not establish the case of the ownership of chassis after being sold by the VIPL to the respondent continued to vest on the chassis manufacturer i.e., M/s VIPL. Further, the Tribunal held that applying the very same analogy, there is no inference to lead that merely on the basis of Technology License Contract dated 01.01.2008 between M/s Volvo Bus Corporation, Sweden (VBC) and the respondent for the legal ownership of the chassis continued to remain, the chassis manufacturer i.e., VIPL, since it belongs to the same group of companies i.e., ‘AB Volvo’, Sweden. 10. The Tribunal on these aspects of the matter, held that the respondent before it is admitted and are eligible to the benefit of exemption provided under Notification stated supra. 11. Having held so, the Tribunal allowed the appeal setting aside the order in original passed by the Commissioner. 10. The Tribunal on these aspects of the matter, held that the respondent before it is admitted and are eligible to the benefit of exemption provided under Notification stated supra. 11. Having held so, the Tribunal allowed the appeal setting aside the order in original passed by the Commissioner. It is this order passed by the Tribunal that is called in question by the revenue in this appeal on the following substantial questions of law: (i) WHETHER, the CESTAT has committed an error in ignoring the definition or related person contained in Section 4 of the Central Excise Act which disentitles the Respondent from claiming the benefit of Notification No.6/2006 and 12/2012? (ii) WHETHER in the facts of the case, the CESTAT is right in applying the concept of ownership contrary to the provisions contained in Section 4 of the Central Excise Act with respect to related person and inter-connected undertakings? (iii) WHETHER under the facts of the case, the CESTAT is right in holding that the ownership over the chassis was transferred to the Respondent particularly in the light of the fact that the supplier of chassis (VIPL) and the Respondent are interconnected undertakings and the vehicles were manufactured by chassis manufactured on its own account leading to perversity? (iv) WHETHER, the CESTAT is right in allowing the appeal of the Respondent without appreciating the intent and object of the Notifications and by not appreciating that the various clauses in the agreement between the Respondent and its Group Companies thereby leading to perversity? 12. Heard Sri.Jeevan J.Neeralagi, learned counsel for appellant/Revenue and Sri.Ravi Raghavan along with Sri.Nischal K.M, learned counsel for respondent. 13. Sri.Jeevan J.Neeralagi, reiterating the very same contentions taken before the Tribunal, urges before us that, in view of Section 4 which refers to 'related person', the respondent though shown as separate entity, but both companies are under the same management and are owned and controlled by a common entity i.e. 'AB Volvo', Sweden, are inter connected undertakings having activities in India. As such covered under the expression ‘related person’ envisaged under Section 4 of the C.E. Act. He further submits that once Section 4 is read with Notification No.6/2006 dated 01.03.2006 and 12/2012, it disentitles the respondent from claiming any benefit of exemptions provided under the Notifications supra. 14. As such covered under the expression ‘related person’ envisaged under Section 4 of the C.E. Act. He further submits that once Section 4 is read with Notification No.6/2006 dated 01.03.2006 and 12/2012, it disentitles the respondent from claiming any benefit of exemptions provided under the Notifications supra. 14. The learned counsel underscores his arguments on the point 'related person', inasmuch as both the entities in India operating their activities are owned and controlled by a common entity 'AB Volvo', Sweden, though the chassis were shown to be sold, still the ownership continues with M/s VIPL (manufacturer of chassis), being part of the same entity. In these circumstances, respondent is not entitled for any benefit under the Notification to claim exemption. 15. Learned counsel further emphasizes that the Commissioner having properly considered the entire material placed, before it passed the original order, holding that the respondent is not entitled for any benefit under the Notification and is liable to pay the amount of duty to the extent stated therein. The Tribunal failed to consider these aspects of the matter which are crucial for the decision on exemption which requires interference by admitting the appeal on substantial questions of law raised in favour of Revenue. 16. Refuting the contentions of Sri.Neeralagi, Sri.Ravi Raghavan, taking us through the judgment of Tribunal, argues placing reliance, especially on paragraph Nos.11 to 13, that the Tribunal has opined that the observation and findings by the original authority is out of context, inasmuch as the question is not for determination of the value of the chassis sold, as such, even invoking Section 4 on the basis of interconnected undertaking is also irrelevant. 17. Sri.Ravi Raghavan further submits that the Tribunal having considered the entire material before it has come to the conclusion that the respondent and VIPL are carrying on/operating their business independently in India and the respondent having paid the entire payment, the transfer of ownership of the chassis is completed on it, in terms of sale, in view of definition provided under Section 2(h) of the Central Excise Act, 1944. On this Sri.Ravi Raghavan contends that there remains nothing to contend that, ownership still vests with the manufacturer of chassis, on the premise that they are being part of the same common entity. On this Sri.Ravi Raghavan contends that there remains nothing to contend that, ownership still vests with the manufacturer of chassis, on the premise that they are being part of the same common entity. In view of the fact that, both the respondent and VIPL are distinct legal entities, operating in India, since both are incorporated independently under the India Companies Act, 1956. 18. He further argues that there is no condition appended to the sale, which would indicate that despite sale, the transfer of possession is incomplete. Sri.Ravi Raghavan submits that the Tribunal being the last finding authority has passed a considered and reasoned order allowing the appeal, setting aside the order impugned, holding that the respondent is entitled for the benefit under the Notification for having fulfilled the conditions for claiming exemption, which we have already extracted above. The learned counsel accordingly, sought to dismiss the appeal. 19. Having heard the learned counsels appearing for the parties, we have gone through the entire orders passed by the Tribunal, as well as the original authority. The Tribunal, especially at paragraph Nos.11 to 13, as has been pointed out by the learned counsel appearing for the respondent, in the facts of the case has come to conclusion that both the entities carrying on their activities in India are totally different and independent entities incorporated under the Indian Companies Act, and it cannot be held that one has control over the other in the premise that they are part of a common group of companies. The VIPL is manufacturing chassis and once chassis has been sold in favour of respondent, on payment of full price towards it, the ownership transfers in favour of the respondent under sale as stated under Section 2(h) of the Central Excise Act, 1944. 20. The substantial questions raised have already been answered by the Tribunal against the Revenue, while appreciating the facts before it. In the circumstances, nothing survives for consideration in the present appeal. In other words, no substantial question of law emerges before us, in the appeal which warrants any interference in the order passed by the Tribunal. 21. In view of the fact that the Tribunal has answered all the contentions raised by the Revenue in its order, especially at paragraph Nos. 11 to 13, the order impugned does not require any interference at the hands of this Court. 22. 21. In view of the fact that the Tribunal has answered all the contentions raised by the Revenue in its order, especially at paragraph Nos. 11 to 13, the order impugned does not require any interference at the hands of this Court. 22. For the foregoing reasons, we pass the following: ORDER: The appeal fails, as no substantial questions of law are made out for determination. Accordingly, appeal is dismissed.