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Batter-coated, deep-fried Tasty Peanuts containing gram flour, salt and spices constitute a distinct food preparation classified under the food-preparation tariff entry, attracting the stated exemption. Oil-fried Salted Peanuts with salt alone remain within the specific ground-nut entry because it expressly covers nuts roasted in oil or fat with salt, flavours or spices; their exemption is unavailable. ISD-distributed CENVAT credit is available to an authorised contract manufacturing unit producing dutiable goods for the principal, with subsequent amendments curing the earlier lacuna from inception. Penalties do not arise from bona fide tariff-classification and CENVAT-credit interpretation disputes without fraud, suppression, collusion, wilful intent to evade duty or mens rea.
Batter-coated, deep-fried Tasty Peanuts containing gram flour, salt and spices constitute a distinct food preparation classified under the food-preparation tariff entry, attracting the stated exemption. Oil-fried Salted Peanuts with salt alone remain within the specific ground-nut entry because it expressly covers nuts roasted in oil or fat with salt, flavours or spices; their exemption is unavailable. ISD-distributed CENVAT credit is available to an authorised contract manufacturing unit producing dutiable goods for the principal, with subsequent amendments curing the earlier lacuna from inception. Penalties do not arise from bona fide tariff-classification and CENVAT-credit interpretation disputes without fraud, suppression, collusion, wilful intent to evade duty or mens rea.
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