https://www.taxtmi.com/caselaws?id=80196 The definition of "manufacturer" under the Central Excises & Salt Act, 1944 is descriptive and does not require physical production alone; where two reasonable inferences are possible on who manufactured excisable goods, the inference favourable to the assessee must prevail. On the admitted facts, the boilers belonged to the neighbouring unit, were directly connected to its factory, and the evidence did not conclusively establish that the appellant itself manufactured the steam, so the appellant was not proved to be the real manufacturer. The extended limitation period also required proof of deliberate suppression or fraud; since steam production was disclosed in the classification list and no wilful concealment was shown, extended limitation was not justified. en-us Tue, 21 Nov 1989 00:00:00 +0530 Wed, 15 Jun 2011 13:02:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=80196 The definition of "manufacturer" under the Central Excises & Salt Act, 1944 is descriptive and does not require physical production alone; where two reasonable inferences are possible on who manufactured excisable goods, the inference favourable to the assessee must prevail. On the admitted facts, the boilers belonged to the neighbouring unit, were directly connected to its factory, and the evidence did not conclusively establish that the appellant itself manufactured the steam, so the appellant was not proved to be the real manufacturer. The extended limitation period also required proof of deliberate suppression or fraud; since steam production was disclosed in the classification list and no wilful concealment was shown, extended limitation was not justified. Case-Laws Central Excise Tue, 21 Nov 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=80196