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    <title>2026 (4) TMI 1225 - CESTAT BANGALORE</title>
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    <description>Granulation of phosphogypsum, dolomite and bentonite into a marketable soil conditioner was treated as manufacture because the process produced a product with a distinct character and use, and it was not a mere physical mixing exercise. The note also states that, in the absence of a specific tariff entry for soil conditioner, classification under Chapter Heading 3103 was not sustained on the facts discussed. Where the assessee had already disclosed manufacture to the Department, omission to report the product in ER-1 returns did not amount to suppression, so extended limitation and penalty were not justified.</description>
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