https://www.taxtmi.com/caselaws?id=345363 A duty demand cannot be sustained on a statutory basis that was not invoked in the show cause notice or adjudication order, as the notice remains the foundation for levy, interest, and penalty. The text also states that a job-work arrangement did not, by itself, prove manufacture on behalf of the appellant because no evidence showed the required control or agency nexus. In a revenue-neutral export setting, where duty paid on inputs would have been refundable, mala fide intent could not be inferred; the extended period of limitation and penalties were therefore not attracted. The article notes that the impugned order was set aside and relief followed in full. 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 A duty demand cannot be sustained on a statutory basis that was not invoked in the show cause notice or adjudication order, as the notice remains the foundation for levy, interest, and penalty. The text also states that a job-work arrangement did not, by itself, prove manufacture on behalf of the appellant because no evidence showed the required control or agency nexus. In a revenue-neutral export setting, where duty paid on inputs would have been refundable, mala fide intent could not be inferred; the extended period of limitation and penalties were therefore not attracted. The article notes that the impugned order was set aside and relief followed in full. Case-Laws Central Excise Mon, 24 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=345363