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    <title>1998 (11) TMI 173 - CEGAT, NEW DELHI</title>
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    <description>Grinding and crushing felspar lumps into felspar powder was treated as manufacture because the process produced a new marketable commodity, making the powder excisable under the tariff heading invoked. The clearances of independent job workers could not be clubbed with those of the principal manufacturer, as the record did not show dummy units or a mere labour arrangement and the work was on a principal-to-principal basis. For limitation and penalty, conflicting views on taxability supported a bona fide belief that the goods were not dutiable, so the extended period was unavailable and penalty could not be sustained; the demand was confined to the normal period.</description>
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      <title>1998 (11) TMI 173 - CEGAT, NEW DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=89431</link>
      <description>Grinding and crushing felspar lumps into felspar powder was treated as manufacture because the process produced a new marketable commodity, making the powder excisable under the tariff heading invoked. The clearances of independent job workers could not be clubbed with those of the principal manufacturer, as the record did not show dummy units or a mere labour arrangement and the work was on a principal-to-principal basis. For limitation and penalty, conflicting views on taxability supported a bona fide belief that the goods were not dutiable, so the extended period was unavailable and penalty could not be sustained; the demand was confined to the normal period.</description>
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