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    <title>2015 (10) TMI 1725 - CESTAT AHMEDABAD (LB)</title>
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    <description>Blending guar dal powder with tamarind kernel powder and additives was treated as manufacture because the process changed the product&#039;s character, viscosity and commercial identity into a distinct article. The resultant goods were held classifiable under Heading 1301 as gum, not under Heading 1101, and the broader tariff meaning was preferred over a restrictive distinction between seed gums and plant exudates. However, extended limitation and penalties were found unsustainable where the assessee had disclosed the process, the dispute was one of classification, and the belief adopted was bona fide; relief was therefore granted on limitation and penalty, with duty confined to the normal period.</description>
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      <description>Blending guar dal powder with tamarind kernel powder and additives was treated as manufacture because the process changed the product&#039;s character, viscosity and commercial identity into a distinct article. The resultant goods were held classifiable under Heading 1301 as gum, not under Heading 1101, and the broader tariff meaning was preferred over a restrictive distinction between seed gums and plant exudates. However, extended limitation and penalties were found unsustainable where the assessee had disclosed the process, the dispute was one of classification, and the belief adopted was bona fide; relief was therefore granted on limitation and penalty, with duty confined to the normal period.</description>
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