https://www.taxtmi.com/caselaws?id=441957 Refilling liquid oxygen and liquid argon from bulk containers into returnable retail cylinders, with identification labelling and conversion into gaseous form, does not constitute manufacture under Chapter Note 9 to Chapter 28 where the process neither repacks bulk packs into retail packs in the statutory sense nor creates a new marketable product. Mixing argon and carbon dioxide similarly remains outside manufacture when the gases retain their individual properties. Extended limitation cannot be invoked where the department knew of the activity and the dispute is interpretational, without established suppression, fraud, collusion or wilful misstatement. Consequently, the demand, penalty and confiscation were unsustainable. 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 returnable retail cylinders, with identification labelling and conversion into gaseous form, does not constitute manufacture under Chapter Note 9 to Chapter 28 where the process neither repacks bulk packs into retail packs in the statutory sense nor creates a new marketable product. Mixing argon and carbon dioxide similarly remains outside manufacture when the gases retain their individual properties. Extended limitation cannot be invoked where the department knew of the activity and the dispute is interpretational, without established suppression, fraud, collusion or wilful misstatement. Consequently, the demand, penalty and confiscation were unsustainable. Case-Laws Central Excise Mon, 24 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=441957