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    <title>2016 (1) TMI 477 - CESTAT MUMBAI</title>
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    <description>R acking and relabelling by a 100% EOU are treated under the EXIM Policy as manufacture, because that policy defines manufacture more broadly than section 2(f) of the Central Excise Act and expressly includes such processes. If the imported or domestically procured goods were so processed before export, they would not be treated as exported as such and the exemption under Notification No. 22/2003-C.E. and Notification No. 52/2003-Cus. could be sustained. As the factual claim of repacking and relabelling and the plea of revenue neutrality through export drawback had not been examined, fresh de novo adjudication on facts was considered necessary.</description>
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