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    <description>Differential duty and penalties could not be sustained against a buyer company and its directors where the goods were manufactured by an independent supplier that used its own raw materials and leased capital goods, filed returns, and paid duty. Mere deputation of supervisors, financial advances adjusted against sale consideration, or influence over job charges did not establish that the supplier was a dummy or facade of the buyer. As the department itself had accepted the supplier as the manufacturer, the demand against the buyer lacked legal foundation and was set aside.</description>
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