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    <title>2018 (8) TMI 14 - CESTAT AHMEDABAD</title>
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    <description>Printing on bought-out PVC sheets was held not to amount to manufacture because Chapter Note 10 to Chapter 39 treats printed and unprinted PVC sheets within the same tariff category and the process did not create a new commercially distinct product. The demand based on manufacture therefore failed. On limitation, the extended period could not be invoked because the dispute involved a pure question of law, there were conflicting judicial views, and the belief that printing was not manufacture was found bona fide, with no suppression or intent to evade duty established. The impugned orders were set aside and the demand and penalties did not survive.</description>
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      <link>https://www.taxtmi.com/caselaws?id=364542</link>
      <description>Printing on bought-out PVC sheets was held not to amount to manufacture because Chapter Note 10 to Chapter 39 treats printed and unprinted PVC sheets within the same tariff category and the process did not create a new commercially distinct product. The demand based on manufacture therefore failed. On limitation, the extended period could not be invoked because the dispute involved a pure question of law, there were conflicting judicial views, and the belief that printing was not manufacture was found bona fide, with no suppression or intent to evade duty established. The impugned orders were set aside and the demand and penalties did not survive.</description>
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