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    <title>2025 (11) TMI 1538 - CESTAT MUMBAI</title>
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    <description>Specially designed drip-irrigation components were treated as parts of a functional irrigation system under Heading 8424 and therefore eligible for the relevant exemption, as they were not ordinary plastic tubes of general use. The Tribunal also found no independent corroborative evidence of clandestine manufacture or unrecorded removals because the assessee had maintained statutory records, filed returns, and produced invoices and reconciliation material. As the classification issue was resolved in the assessee&#039;s favour and suppression was not proved, the extended period of limitation, Modvat-related objection, and consequential penalties were held unsustainable.</description>
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      <description>Specially designed drip-irrigation components were treated as parts of a functional irrigation system under Heading 8424 and therefore eligible for the relevant exemption, as they were not ordinary plastic tubes of general use. The Tribunal also found no independent corroborative evidence of clandestine manufacture or unrecorded removals because the assessee had maintained statutory records, filed returns, and produced invoices and reconciliation material. As the classification issue was resolved in the assessee&#039;s favour and suppression was not proved, the extended period of limitation, Modvat-related objection, and consequential penalties were held unsustainable.</description>
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