https://www.taxtmi.com/caselaws?id=269439 Cold-rolling of hot-rolled stainless steel patta/pattis was treated as manufacture under Central Excise law because the process caused strain hardening, altered crystalline structure, increased hardness and tensile strength, and produced goods with a distinct physical character, use, and market identity. Chapter Note 4 to Chapter 72 was read as deeming hardening or tempering by cold-rolling of flat-rolled products to be manufacture, supported by the HSN explanatory notes. The extended limitation period under the proviso to Section 11A was also upheld because the assessee had not taken registration or paid duty, and the surrounding facts negated bona fide belief and suppression arguments. en-us Mon, 14 Dec 2015 00:00:00 +0530 Thu, 04 Feb 2016 14:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=269439 Cold-rolling of hot-rolled stainless steel patta/pattis was treated as manufacture under Central Excise law because the process caused strain hardening, altered crystalline structure, increased hardness and tensile strength, and produced goods with a distinct physical character, use, and market identity. Chapter Note 4 to Chapter 72 was read as deeming hardening or tempering by cold-rolling of flat-rolled products to be manufacture, supported by the HSN explanatory notes. The extended limitation period under the proviso to Section 11A was also upheld because the assessee had not taken registration or paid duty, and the surrounding facts negated bona fide belief and suppression arguments. Case-Laws Central Excise Mon, 14 Dec 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=269439