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    <title>2026 (3) TMI 1632 - Supreme Court</title>
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    <description>An exemption notification tied to intended use was construed to require procurement and use for the stated manufacture, not exclusive or directly traceable consumption in each end-product unit. Naphtha obtained on CT-2 certificates for fertilizer and ammonia production did not lose exemption merely because it was used as supplementary fuel in an integrated steam-generation system serving multiple plant units, where the electricity generated was largely deployed in fertilizer operations. The extended limitation period and penalty depended on fraud, suppression or intent to evade duty; mere disagreement on exemption eligibility or difficulty in segregating fuel use was insufficient, especially in a revenue-neutral setting. On that basis, the demand, interest and penalties were set aside.</description>
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      <link>https://www.taxtmi.com/caselaws?id=788877</link>
      <description>An exemption notification tied to intended use was construed to require procurement and use for the stated manufacture, not exclusive or directly traceable consumption in each end-product unit. Naphtha obtained on CT-2 certificates for fertilizer and ammonia production did not lose exemption merely because it was used as supplementary fuel in an integrated steam-generation system serving multiple plant units, where the electricity generated was largely deployed in fertilizer operations. The extended limitation period and penalty depended on fraud, suppression or intent to evade duty; mere disagreement on exemption eligibility or difficulty in segregating fuel use was insufficient, especially in a revenue-neutral setting. On that basis, the demand, interest and penalties were set aside.</description>
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