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Conversion of imported manganese ore into concentrates was treated as manufacture under the relevant statutory definition and the Chapter Note deeming provision, leading to classification as manganese concentrates under Chapter Heading 2602 and denial of exemption from countervailing duty on import. The Tribunal applied precedents holding that screening, sizing and crushing of ROM ore producing concentrates creates distinct excisable goods under the HSN explanation, and therefore exemption at import is not available. Separately, statutory liability for interest on delayed payment of duty was affirmed, requiring payment of applicable interest.
Conversion of imported manganese ore into concentrates was treated as manufacture under the relevant statutory definition and the Chapter Note deeming provision, leading to classification as manganese concentrates under Chapter Heading 2602 and denial of exemption from countervailing duty on import. The Tribunal applied precedents holding that screening, sizing and crushing of ROM ore producing concentrates creates distinct excisable goods under the HSN explanation, and therefore exemption at import is not available. Separately, statutory liability for interest on delayed payment of duty was affirmed, requiring payment of applicable interest.
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