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    <title>2019 (2) TMI 1225 - CESTAT AHMEDABAD</title>
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    <description>Repacking and relabelling of imported goods was treated as not amounting to manufacture under Chapter Note 10 of Chapter 29, because the activity was limited to repacking and relabelling and did not, on the settled position stated in the text, itself create a manufactured product. On limitation, the extended period could not be invoked where the liability issue turned on a bona fide and reasonably debatable interpretation of the chapter note, supported by consistent departmental practice, and there was no suppression or mala fide intent to evade duty. The demand was therefore time-barred and the impugned order was set aside.</description>
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      <link>https://www.taxtmi.com/caselaws?id=375598</link>
      <description>Repacking and relabelling of imported goods was treated as not amounting to manufacture under Chapter Note 10 of Chapter 29, because the activity was limited to repacking and relabelling and did not, on the settled position stated in the text, itself create a manufactured product. On limitation, the extended period could not be invoked where the liability issue turned on a bona fide and reasonably debatable interpretation of the chapter note, supported by consistent departmental practice, and there was no suppression or mala fide intent to evade duty. The demand was therefore time-barred and the impugned order was set aside.</description>
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