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    <title>2018 (1) TMI 1435 - CESTAT AHMEDABAD</title>
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    <description>Repacking and relabelling of imported inputs was treated by the assessee as manufacture, but the activity was held to be only repacking and relabelling under the relevant chapter note and settled precedent. Because the legal position was debatable, the assessee had disclosed the activity, and the department had earlier taken a similar view, bona fide belief was accepted and suppression or mala fide intent to evade duty could not be inferred. The notice was issued beyond the normal limitation period, so the extended period of limitation was not available and the demand was time-barred.</description>
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      <description>Repacking and relabelling of imported inputs was treated by the assessee as manufacture, but the activity was held to be only repacking and relabelling under the relevant chapter note and settled precedent. Because the legal position was debatable, the assessee had disclosed the activity, and the department had earlier taken a similar view, bona fide belief was accepted and suppression or mala fide intent to evade duty could not be inferred. The notice was issued beyond the normal limitation period, so the extended period of limitation was not available and the demand was time-barred.</description>
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