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Gold coins embossed with Goddess Lakshmi were treated as articles of gold, not bullion, under the common parlance test. Applying M/s. G.S. Pai & Co., the court said bullion means gold in raw or unwrought form, such as bars or ingots; once metal is manufactured into coins with embossing, engraving and weight marking, it acquires a distinct commercial identity. Because the coins were sold with value addition and not at bullion rates, the higher tax classification as articles of gold was upheld and the bullion classification rejected.
Gold coins embossed with Goddess Lakshmi were treated as articles of gold, not bullion, under the common parlance test. Applying M/s. G.S. Pai & Co., the court said bullion means gold in raw or unwrought form, such as bars or ingots; once metal is manufactured into coins with embossing, engraving and weight marking, it acquires a distinct commercial identity. Because the coins were sold with value addition and not at bullion rates, the higher tax classification as articles of gold was upheld and the bullion classification rejected.
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