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    <title>1973 (9) TMI 93 - MADRAS HIGH COURT</title>
    <link>https://www.taxtmi.com/caselaws?id=150729</link>
    <description>A manure mixture made from one or more chemical fertilisers listed in item 21 was treated as a chemical fertiliser within that entry because the expression was construed broadly and the words &quot;that is to say&quot; were not limiting. A mixture that acquires different chemical properties and is marketed as a distinct commercial product loses identity with its component fertilisers, so the second sale exemption does not apply unless the goods remain the same at both stages. Whether the process amounted to manufacture was immaterial to classification. The mixture was therefore not a second sale of the original fertilisers, and the Tribunal&#039;s contrary view was unsustainable.</description>
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    <pubDate>Tue, 18 Sep 1973 00:00:00 +0530</pubDate>
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      <title>1973 (9) TMI 93 - MADRAS HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=150729</link>
      <description>A manure mixture made from one or more chemical fertilisers listed in item 21 was treated as a chemical fertiliser within that entry because the expression was construed broadly and the words &quot;that is to say&quot; were not limiting. A mixture that acquires different chemical properties and is marketed as a distinct commercial product loses identity with its component fertilisers, so the second sale exemption does not apply unless the goods remain the same at both stages. Whether the process amounted to manufacture was immaterial to classification. The mixture was therefore not a second sale of the original fertilisers, and the Tribunal&#039;s contrary view was unsustainable.</description>
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      <pubDate>Tue, 18 Sep 1973 00:00:00 +0530</pubDate>
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