https://www.taxtmi.com/caselaws?id=441957 Refilling liquid oxygen and liquid argon from bulk containers into retail cylinders, with labeling and conversion from liquid to gaseous form, is stated not to amount to manufacture under Chapter Note 9 to Chapter 28 read with section 2(f) because mere transfer between containers and identification labeling do not create a new marketable product or a product having a distinct character. The note applies only where the process brings about marketability in the statutory sense. It also states that the extended limitation period is unavailable where the dispute is interpretational and there is no proved suppression, fraud, collusion, or wilful misstatement; on that basis, demand, penalty, and confiscation could not be sustained. en-us Mon, 24 Jul 2023 00:00:00 +0530 Mon, 21 Aug 2023 18:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=441957 Refilling liquid oxygen and liquid argon from bulk containers into retail cylinders, with labeling and conversion from liquid to gaseous form, is stated not to amount to manufacture under Chapter Note 9 to Chapter 28 read with section 2(f) because mere transfer between containers and identification labeling do not create a new marketable product or a product having a distinct character. The note applies only where the process brings about marketability in the statutory sense. It also states that the extended limitation period is unavailable where the dispute is interpretational and there is no proved suppression, fraud, collusion, or wilful misstatement; on that basis, demand, penalty, and confiscation could not be sustained. Case-Laws Central Excise Mon, 24 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=441957