https://www.taxtmi.com/caselaws?id=51017 A procurer of Khandsari molasses deemed to be the manufacturer under Rule 7A and the amended Rule 9/Rule 9C only for duty recovery cannot extend that legal fiction to claim small scale industry exemption under Notification No. 7/97. The fiction operates solely for collection and recovery of duty and does not convert the procurer into an actual manufacturer for exemption purposes. Because the notification conditions require manufacture in a factory, the procurer does not satisfy the scheme's eligibility requirements. The stated principle is that a legal fiction must be carried to its logical purpose but no further, and the exemption is therefore unavailable to the procurer. en-us Fri, 02 Nov 2001 00:00:00 +0530 Tue, 21 Sep 2010 14:03:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=51017 A procurer of Khandsari molasses deemed to be the manufacturer under Rule 7A and the amended Rule 9/Rule 9C only for duty recovery cannot extend that legal fiction to claim small scale industry exemption under Notification No. 7/97. The fiction operates solely for collection and recovery of duty and does not convert the procurer into an actual manufacturer for exemption purposes. Because the notification conditions require manufacture in a factory, the procurer does not satisfy the scheme's eligibility requirements. The stated principle is that a legal fiction must be carried to its logical purpose but no further, and the exemption is therefore unavailable to the procurer. Case-Laws Central Excise Fri, 02 Nov 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=51017