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    <title>2015 (3) TMI 826 - CESTAT MUMBAI</title>
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    <description>Where furniture and carpentry work was assigned to independent sub-contractors on a principal-to-principal basis, the real manufacturer was treated as the sub-contractor because the appellants did not control the labour and the agreements showed independent performance responsibility. In a classification and exemption dispute marked by bona fide interpretative uncertainty, the extended period of limitation was held unavailable in the absence of specific allegations of wilful suppression or fraud. As the demand was time-barred, the consequential interest and penalty claims, including personal penalty, were held not sustainable; one member dissented on the manufacturer issue and treated the appellants as manufacturers.</description>
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      <title>2015 (3) TMI 826 - CESTAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=257892</link>
      <description>Where furniture and carpentry work was assigned to independent sub-contractors on a principal-to-principal basis, the real manufacturer was treated as the sub-contractor because the appellants did not control the labour and the agreements showed independent performance responsibility. In a classification and exemption dispute marked by bona fide interpretative uncertainty, the extended period of limitation was held unavailable in the absence of specific allegations of wilful suppression or fraud. As the demand was time-barred, the consequential interest and penalty claims, including personal penalty, were held not sustainable; one member dissented on the manufacturer issue and treated the appellants as manufacturers.</description>
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