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    <title>2026 (3) TMI 1588 - CESTAT CHENNAI</title>
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    <description>Post-clearance sale of vehicles manufactured on job work basis through Regional Sales Offices was not trading, because the goods were first manufactured and cleared on payment of duty and no independent purchase-resale activity was shown. Rule 6(3) of the CENVAT Credit Rules, 2004 did not apply because no separate exempted service or identifiable common input service nexus with alleged trading was established, so credit reversal or payment was not warranted. The extended limitation also failed since the transactions were disclosed in statutory records and no suppression or wilful misstatement was proved; the penalties based on the demand therefore could not survive.</description>
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      <description>Post-clearance sale of vehicles manufactured on job work basis through Regional Sales Offices was not trading, because the goods were first manufactured and cleared on payment of duty and no independent purchase-resale activity was shown. Rule 6(3) of the CENVAT Credit Rules, 2004 did not apply because no separate exempted service or identifiable common input service nexus with alleged trading was established, so credit reversal or payment was not warranted. The extended limitation also failed since the transactions were disclosed in statutory records and no suppression or wilful misstatement was proved; the penalties based on the demand therefore could not survive.</description>
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