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    <title>2025 (12) TMI 1193 - CESTAT CHENNAI</title>
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    <description>Cutting/slitting of HR/CR coils was held not to amount to &quot;manufacture&quot;, applying the binding ratio of Del HC affirmed by SC and the CBEC circular withdrawing contrary guidance; the assessee&#039;s contrary treatment was rejected and the issue was decided for Revenue. Since no manufacture occurred, HR/CR coils could not qualify as &quot;inputs&quot; under Rule 2(k) CCR, making CENVAT credit inadmissible ab initio and rendering Rule 3(5) inapplicable; recovery of credit with interest was upheld. Inflated valuation was found to be a colourable device to encash/pass on lapsed credit; the overvaluation charge was sustained. Amounts collected as &quot;duty&quot; on non-excisable goods attracted s.11D(1A); deposit was confirmed. Suppression/misstatement justified the extended period and penalty under s.11AC; the appeal was dismissed.</description>
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    <pubDate>Thu, 18 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1193 - CESTAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=783653</link>
      <description>Cutting/slitting of HR/CR coils was held not to amount to &quot;manufacture&quot;, applying the binding ratio of Del HC affirmed by SC and the CBEC circular withdrawing contrary guidance; the assessee&#039;s contrary treatment was rejected and the issue was decided for Revenue. Since no manufacture occurred, HR/CR coils could not qualify as &quot;inputs&quot; under Rule 2(k) CCR, making CENVAT credit inadmissible ab initio and rendering Rule 3(5) inapplicable; recovery of credit with interest was upheld. Inflated valuation was found to be a colourable device to encash/pass on lapsed credit; the overvaluation charge was sustained. Amounts collected as &quot;duty&quot; on non-excisable goods attracted s.11D(1A); deposit was confirmed. Suppression/misstatement justified the extended period and penalty under s.11AC; the appeal was dismissed.</description>
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      <pubDate>Thu, 18 Dec 2025 00:00:00 +0530</pubDate>
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