Commissioner of Central Excise, MumbaiII .... Respondent 9th Floor, Piramal Chambers Lalbaug, Parel, Mumbai 400 012. Appearance: Ms. Mansi Patil, Advocate for the Appellants Shri P.K. Acharya, Authorized Representative for the Respondent HON'BLE MR. S.K. MOHANTY, MEMBER (JUDICIAL) HON'BLE MR. M.M. PARTHIBAN, MEMBER (TECHNICAL) FINAL ORDER NO. A/86733/2025 Date of Hearing: 30.07.2025 Date of Decision: 30.10.2025 Per: M.M. PARTHIBAN This appeal has been filed by M/s Hindustan Petroleum Corporation Limited (HPCL), Refinery Division, Mahul, Mumbai (herein after, referred to as "the appellants", for short) assailing the OrderinAppeal No. PK/40/M II/2016 dated 21.09.2016 (herein after, referred to as "the impugned order") passed by the Commissioner of Central Excise (Appeals), Mumbai ZoneII. 2. Revenue has filed this miscellaneous application seeking for change of name and address of the respondent arising on account of change in 2 E/87516/2016 jurisdiction of the Central Excise authorities. The prayer made by the Revenue is considered and accordingly, the Registry is directed to incorporate the following changed name and address of the respondent in the appeal records for the purpose of disposal of the appeal: "Commissioner of Central Goods Service Tax & Central Excise, Navi Mumbai Commissionerate, 16th Floor, Satra Plaza, Sector 19D, Palm Beach Road, Vashi, Navi Mumbai 400 705". 3.1 Brief facts of the case, leading to this appeal, are summarized herein below: 3.2. The appellants herein is engaged inter alia, in the manufacturer of petroleum products by refining of crude petroleum and marketing of various finished products viz., HighSpeed Diesel (HSD), Motor Sprit (MS), Superior Kerosene Oil (SKO), Aviation Turbine Fuel (ATF), Lube Oil etc. by classifying the aforesaid products under Chapter 25, 27 of the First Schedule to the Central Excise Tariff Act, 1985. The appellants are registered taxpayers holding Central Excise Registration No. AAACH1118BXM010 for manufacture of aforesaid excisable goods on payment appropriate Central Excise duty of and for compliance with Central Excise statue. 3.3 The excisable goods viz., HSD, MS and SKO manufactured at Mahul refinery are transported to their different depots situated at Vashi, Pakni, Lone and Hazarwadi through pipelines called MumbaiPuneSolapur pipeline (MPSPL) from where sales to retailers takes place. The pipeline transfers of aforesaid goods on payment of applicable duty are made by the appellants in the form batch of shipments, following a sequential producttoproduct pumping method, whereby at any one point of time only one product in the pipeline is pushed through. However, upon completion of pumping of one product, say HSD or MS, the other product i.e., SKO is introduced in the pipeline which pushes the other product without any positive segregation. Therefore, the line connected of each consignment of the products may comprise of a mixture of two products, during the time of shifting from one product to another, which is known as "interface" or "transmix" at the interjunction of each batch of product. Such interface/transmix products are taken into specific tanks at the destination as per laid down safety norms and operational procedures has prescribed under Industry Quality Control Manual (ICQM). 3 E/87516/2016 3.4 As a conventional practice, the appellants were using SKO as an interface between MS and HSD, since intermixing of MS and HSD or HSD and MS will contaminate the entire product. The Department had interpreted that the offsetting of gain observed in one product say MS/HSD against the loss observed in another product say SKO, though the duty payable on the