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CESTAT held that Appellant's processing of imported steel wire ropes through cutting, fusing, crimping with accessories, and packaging as "Gripple Hanger System" constituted manufacture under Central Excise Act. The processed product emerged as distinct commodity with separate name, character, use, and higher marketability than individual components. However, CESTAT partially allowed appeal on limitation grounds. Revenue failed to establish intent to evade duty or suppression of facts warranting extended limitation period under Section 11A(4). Show cause notice based merely on audit objection without cogent evidence of willful suppression cannot invoke extended period. Excise duty demand within normal limitation period upheld; demand and penalty for extended period set aside as time-barred.
CESTAT held that Appellant's processing of imported steel wire ropes through cutting, fusing, crimping with accessories, and packaging as "Gripple Hanger System" constituted manufacture under Central Excise Act. The processed product emerged as distinct commodity with separate name, character, use, and higher marketability than individual components. However, CESTAT partially allowed appeal on limitation grounds. Revenue failed to establish intent to evade duty or suppression of facts warranting extended limitation period under Section 11A(4). Show cause notice based merely on audit objection without cogent evidence of willful suppression cannot invoke extended period. Excise duty demand within normal limitation period upheld; demand and penalty for extended period set aside as time-barred.
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