https://www.taxtmi.com/caselaws?id=43354 In a job-work arrangement, manufacture is attributed to the person who actually carries on the manufacturing process unless the revenue proves that the processors are mere dummies under the assessee's financial, managerial, or supervisory control. The fact that raw material belongs to the assessee is not determinative; the real test is whether the processors operate independently on a principal-to-principal basis. For suppression and extended limitation, the department must show nondisclosure of material facts justifying that allegation; a mere dispute over the true status of the processors is not enough by itself. en-us Fri, 23 Mar 1990 00:00:00 +0530 Thu, 17 Jun 2010 15:49:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=43354 In a job-work arrangement, manufacture is attributed to the person who actually carries on the manufacturing process unless the revenue proves that the processors are mere dummies under the assessee's financial, managerial, or supervisory control. The fact that raw material belongs to the assessee is not determinative; the real test is whether the processors operate independently on a principal-to-principal basis. For suppression and extended limitation, the department must show nondisclosure of material facts justifying that allegation; a mere dispute over the true status of the processors is not enough by itself. Case-Laws Central Excise Fri, 23 Mar 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=43354