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    <title>2019 (2) TMI 1386 - CESTAT CHANDIGARH</title>
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    <description>Refilling ink into containers and relabelling them did not amount to manufacture because the ink retained its identity, character and end use, and no statutory deeming provision applied. A classification not alleged in the show cause notice could not be introduced at adjudication to sustain duty. Where goods were cleared on payment of duty, CVD credit could not be denied merely because the activity was held not to be manufacture. The extended limitation period was unavailable because the assessee disclosed the activity in returns and suppression was not shown. Penalty failed with the underlying demand.</description>
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      <description>Refilling ink into containers and relabelling them did not amount to manufacture because the ink retained its identity, character and end use, and no statutory deeming provision applied. A classification not alleged in the show cause notice could not be introduced at adjudication to sustain duty. Where goods were cleared on payment of duty, CVD credit could not be denied merely because the activity was held not to be manufacture. The extended limitation period was unavailable because the assessee disclosed the activity in returns and suppression was not shown. Penalty failed with the underlying demand.</description>
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