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    <title>2007 (10) TMI 4 - Supreme Court</title>
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    <description>Repacking, filtering and relabelling bulk materials into smaller retail packs may amount to manufacture where the tariff note treats such treatment as rendering the product marketable, and the resulting goods emerge as a distinct commercial commodity. On the facts described, the products were marketed under different names for cleansing use, so they were correctly classified under heading 3402.90 rather than the original headings of the raw materials. The extended period of limitation was also held invocable because the assessee did not fully disclose the nature of the activity, the new product descriptions or their market identity, and the record indicated suppression and incomplete disclosure of material facts.</description>
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      <link>https://www.taxtmi.com/caselaws?id=2168</link>
      <description>Repacking, filtering and relabelling bulk materials into smaller retail packs may amount to manufacture where the tariff note treats such treatment as rendering the product marketable, and the resulting goods emerge as a distinct commercial commodity. On the facts described, the products were marketed under different names for cleansing use, so they were correctly classified under heading 3402.90 rather than the original headings of the raw materials. The extended period of limitation was also held invocable because the assessee did not fully disclose the nature of the activity, the new product descriptions or their market identity, and the record indicated suppression and incomplete disclosure of material facts.</description>
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