Melting and converting imported bullion into bars, coins, medals...

Melting and converting imported bullion into bars, coins, medals and gift items on job-work basis was treated as manufacture because the process produced goods with a distinct character and use. Extended limitation and penalty were rejected because the dispute turned on classification and interpretation, transactions were accounted for, and no intent to evade duty was shown. Gold bars and imported bullion were classified as primary gold under Heading 7108 and held exempt, and branded gold and silver coins made from duty-paid metal were also exempt; medals, medallions and gift items remained dutiable at 1% for the normal period only, while Rule 12AA was held inapplicable.

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