Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
The SC dismissed the appellant's appeal, holding that the process of enclosing the imported genset in a steel container and integrating radiator, fan, filters, tank, pipes, pumps, valves and silencer effects a qualitative transformation such that a new, distinct and marketable commodity (the "Power Pack") emerges. Applying the transformation and marketability tests, the Court found the final product possesses a different character, structure and functional utility (portability) from the imported genset, and is marketed to end customers. The activity therefore constitutes "manufacture" under Section 2(f)(i) of the Act, and the appellant is liable to pay excise duty on the goods manufactured.
The SC dismissed the appellant's appeal, holding that the process of enclosing the imported genset in a steel container and integrating radiator, fan, filters, tank, pipes, pumps, valves and silencer effects a qualitative transformation such that a new, distinct and marketable commodity (the "Power Pack") emerges. Applying the transformation and marketability tests, the Court found the final product possesses a different character, structure and functional utility (portability) from the imported genset, and is marketed to end customers. The activity therefore constitutes "manufacture" under Section 2(f)(i) of the Act, and the appellant is liable to pay excise duty on the goods manufactured.
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