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    <title>2026 (1) TMI 261 - CESTAT KOLKATA</title>
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    <description>Processes undertaken on bought-out items to make couplings under Chapter 84-painting, assembly, fitting, fixing bolts/nuts, and making bore/keyways (including through job workers)-were held to render the goods complete and marketable and therefore constituted &quot;manufacture&quot; under s. 2(f)(ii) of the Central Excise Act read with the relevant Section Note; central excise duty liability on merits was affirmed. However, invocation of the extended limitation period was rejected because the Department had prior knowledge of the activities since 2006 and no suppression was proved; consequently, demands raised on the basis of audit objections for the disputed period were held time-barred and set aside. As intent to evade and suppression were not established, the penalty was also set aside.</description>
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    <pubDate>Fri, 31 Oct 2025 00:00:00 +0530</pubDate>
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      <title>2026 (1) TMI 261 - CESTAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=784505</link>
      <description>Processes undertaken on bought-out items to make couplings under Chapter 84-painting, assembly, fitting, fixing bolts/nuts, and making bore/keyways (including through job workers)-were held to render the goods complete and marketable and therefore constituted &quot;manufacture&quot; under s. 2(f)(ii) of the Central Excise Act read with the relevant Section Note; central excise duty liability on merits was affirmed. However, invocation of the extended limitation period was rejected because the Department had prior knowledge of the activities since 2006 and no suppression was proved; consequently, demands raised on the basis of audit objections for the disputed period were held time-barred and set aside. As intent to evade and suppression were not established, the penalty was also set aside.</description>
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