https://www.taxtmi.com/caselaws?id=32780 An assessee that has no manufacturing facility and fully subcontracts production to independent contractors on a principal-to-principal basis is not the manufacturer of the goods; the contractors are the actual manufacturers, so duty cannot be fastened on the assessee. Where that position is accepted, the extended period of limitation is unjustified and the consequential duty demand, interest and penalty cannot survive. The record also supported a bona fide belief of non-liability, reinforcing the absence of suppression or mala fide conduct. The impugned order was set aside and relief followed. en-us Tue, 24 Jun 2008 00:00:00 +0530 Tue, 31 Mar 2009 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=32780 An assessee that has no manufacturing facility and fully subcontracts production to independent contractors on a principal-to-principal basis is not the manufacturer of the goods; the contractors are the actual manufacturers, so duty cannot be fastened on the assessee. Where that position is accepted, the extended period of limitation is unjustified and the consequential duty demand, interest and penalty cannot survive. The record also supported a bona fide belief of non-liability, reinforcing the absence of suppression or mala fide conduct. The impugned order was set aside and relief followed. Case-Laws Central Excise Tue, 24 Jun 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=32780