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    <title>2026 (4) TMI 798 - CESTAT CHANDIGARH</title>
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    <description>Polishing stainless steel sheets and coils, including satin finish, mirror finish and PVD coating, was treated as resulting in a commercially distinct product, so the activity amounted to manufacture. CENVAT credit on inputs, capital goods and input services was not recoverable again where duty paid on clearance of the finished goods exceeded the credit availed and operated as reversal of that credit. Extended limitation was unavailable because duty had been paid under a bona fide belief of manufacture, the department was aware of the payments, and there was no suppression or intent to evade. The assessee&#039;s position was upheld and the Revenue&#039;s appeal failed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=789729</link>
      <description>Polishing stainless steel sheets and coils, including satin finish, mirror finish and PVD coating, was treated as resulting in a commercially distinct product, so the activity amounted to manufacture. CENVAT credit on inputs, capital goods and input services was not recoverable again where duty paid on clearance of the finished goods exceeded the credit availed and operated as reversal of that credit. Extended limitation was unavailable because duty had been paid under a bona fide belief of manufacture, the department was aware of the payments, and there was no suppression or intent to evade. The assessee&#039;s position was upheld and the Revenue&#039;s appeal failed.</description>
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