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    <title>2005 (2) TMI 805 - ALLAHABAD HIGH COURT</title>
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    <description>Frozen semen was held not to be a &quot;dairy product&quot; under the ordinary meaning of that expression, as it is obtained from a bull and not from milk-based dairy processing; the tax levy therefore stood on that classification issue. Extraction of semen and its preservation in liquid nitrogen did not amount to manufacture because no new commercial product emerged and the process was merely preservative; the dealer was not liable as a manufacturer on that basis. Frozen semen was, however, treated as covered by the livestock exemption notification because it was regarded as a live cell capable of fertilisation; on that ground the assessee succeeded. The revision was dismissed overall.</description>
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    <pubDate>Tue, 22 Feb 2005 00:00:00 +0530</pubDate>
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      <title>2005 (2) TMI 805 - ALLAHABAD HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=162606</link>
      <description>Frozen semen was held not to be a &quot;dairy product&quot; under the ordinary meaning of that expression, as it is obtained from a bull and not from milk-based dairy processing; the tax levy therefore stood on that classification issue. Extraction of semen and its preservation in liquid nitrogen did not amount to manufacture because no new commercial product emerged and the process was merely preservative; the dealer was not liable as a manufacturer on that basis. Frozen semen was, however, treated as covered by the livestock exemption notification because it was regarded as a live cell capable of fertilisation; on that ground the assessee succeeded. The revision was dismissed overall.</description>
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