https://www.taxtmi.com/caselaws?id=1680 Activities limited to random quality checks, sequencing, packing and palletising of bought-out components for export were not treated as manufacture, because the KDP Plant was set up for trading activity and was not shown to be a factory or a premises where manufacture, or any process connected with manufacture, was carried on. The legal fiction of removal of inputs as such did not apply since the goods were not removed from a factory within the statutory sense, and the plea of deemed manufacture was rejected. Cenvat credit on the components exported as such was therefore inadmissible. Penalties for irregular availment of credit were broadly sustained, with one penalty reduced and the others upheld. en-us Wed, 21 Mar 2007 00:00:00 +0530 Tue, 15 Apr 2008 08:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=1680 Activities limited to random quality checks, sequencing, packing and palletising of bought-out components for export were not treated as manufacture, because the KDP Plant was set up for trading activity and was not shown to be a factory or a premises where manufacture, or any process connected with manufacture, was carried on. The legal fiction of removal of inputs as such did not apply since the goods were not removed from a factory within the statutory sense, and the plea of deemed manufacture was rejected. Cenvat credit on the components exported as such was therefore inadmissible. Penalties for irregular availment of credit were broadly sustained, with one penalty reduced and the others upheld. Case-Laws Central Excise Wed, 21 Mar 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=1680