https://www.taxtmi.com/caselaws?id=790156 Granulation of phosphogypsum, dolomite and bentonite into a marketable soil conditioner constitutes manufacture where the process creates a product with a distinct character and use, rather than mere physical mixing. However, soil conditioner is not classifiable under Chapter Heading 3103 solely because it improves soil quality, particularly where no specific tariff entry covers it. Extended limitation and penalty provisions do not apply when manufacture was previously disclosed to the Department and non-reporting in excise returns does not establish suppression. Consequently, the excise demand, interest and penalties were unsustainable. en-us Wed, 15 Apr 2026 00:00:00 +0530 Tue, 21 Apr 2026 08:48:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790156 Granulation of phosphogypsum, dolomite and bentonite into a marketable soil conditioner constitutes manufacture where the process creates a product with a distinct character and use, rather than mere physical mixing. However, soil conditioner is not classifiable under Chapter Heading 3103 solely because it improves soil quality, particularly where no specific tariff entry covers it. Extended limitation and penalty provisions do not apply when manufacture was previously disclosed to the Department and non-reporting in excise returns does not establish suppression. Consequently, the excise demand, interest and penalties were unsustainable. Case-Laws Central Excise Wed, 15 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790156