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    <title>1996 (9) TMI 156 - CEGAT, COURT NO. II, NEW DELHI</title>
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    <description>Fabrication of steel ribs at a tunnel site, where the members were cut, bent and fixed in the earth as part of the civil structure, was treated as non-dutiable because the process did not produce a separately marketable movable commodity. Crushing oversize stones into smaller sizes was held to amount to manufacture because a new commercial commodity emerged, but the demand on that count failed on limitation since the duty issue was debatable and the extended period was unavailable. In the majority view, the duty and penalties were set aside; one member dissented and would have remanded both issues for de novo consideration.</description>
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    <pubDate>Thu, 19 Sep 1996 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=48741</link>
      <description>Fabrication of steel ribs at a tunnel site, where the members were cut, bent and fixed in the earth as part of the civil structure, was treated as non-dutiable because the process did not produce a separately marketable movable commodity. Crushing oversize stones into smaller sizes was held to amount to manufacture because a new commercial commodity emerged, but the demand on that count failed on limitation since the duty issue was debatable and the extended period was unavailable. In the majority view, the duty and penalties were set aside; one member dissented and would have remanded both issues for de novo consideration.</description>
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