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    <title>2024 (12) TMI 1131 - CESTAT AHMEDABAD</title>
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    <description>Tools and fixtures manufactured and retained within the factory for captive use in further manufacture of excisable goods were not liable to excise duty merely because sale invoices were raised, since excise is attracted on clearance and captive consumption for manufacture of other excisable goods falls within Notification No. 67/95-CE. The raising of invoices without physical removal did not by itself create duty liability. For clearances to another unit, where the recipient unit could avail Cenvat Credit of any duty paid, the arrangement was revenue neutral; in that setting, mala fide intent to evade duty could not be presumed and the extended period of limitation was not invocable.</description>
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      <link>https://www.taxtmi.com/caselaws?id=763551</link>
      <description>Tools and fixtures manufactured and retained within the factory for captive use in further manufacture of excisable goods were not liable to excise duty merely because sale invoices were raised, since excise is attracted on clearance and captive consumption for manufacture of other excisable goods falls within Notification No. 67/95-CE. The raising of invoices without physical removal did not by itself create duty liability. For clearances to another unit, where the recipient unit could avail Cenvat Credit of any duty paid, the arrangement was revenue neutral; in that setting, mala fide intent to evade duty could not be presumed and the extended period of limitation was not invocable.</description>
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