https://www.taxtmi.com/caselaws?id=345363 Rule 12B of the Central Excise Rules cannot support a duty demand when it was not invoked in the show cause notice or adjudication order, because liability cannot be founded on a new appellate-stage basis. Job-work processing does not establish manufacture on behalf of a principal unless evidence shows that the job workers manufactured for that principal and were subject to the requisite control. Where inputs are used in exported final goods and any duty would be refundable, revenue neutrality negates an inference of mala fide intent; extended limitation and penalties therefore do not apply. en-us Mon, 24 Apr 2017 00:00:00 +0530 Thu, 03 Aug 2017 11:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=345363 Rule 12B of the Central Excise Rules cannot support a duty demand when it was not invoked in the show cause notice or adjudication order, because liability cannot be founded on a new appellate-stage basis. Job-work processing does not establish manufacture on behalf of a principal unless evidence shows that the job workers manufactured for that principal and were subject to the requisite control. Where inputs are used in exported final goods and any duty would be refundable, revenue neutrality negates an inference of mala fide intent; extended limitation and penalties therefore do not apply. Case-Laws Central Excise Mon, 24 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=345363