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    <title>2026 (4) TMI 1271 - MADRAS HIGH COURT</title>
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    <description>Writ jurisdiction was held maintainable despite an available statutory remedy because the dispute involved a pure question of tariff classification on largely undisputed facts. The assessee was not estopped by an earlier classification, as there is no estoppel against law in tax matters and the Revenue must prove the proposed classification. On merits, drying, stripping and sprinkling raw tobacco with jaggery water did not amount to manufacture, since no new product with a distinct name, character or use emerged. The product was therefore treated as unmanufactured tobacco under CETH 2401 20 90, not chewing tobacco under CETH 2403 99 10.</description>
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      <description>Writ jurisdiction was held maintainable despite an available statutory remedy because the dispute involved a pure question of tariff classification on largely undisputed facts. The assessee was not estopped by an earlier classification, as there is no estoppel against law in tax matters and the Revenue must prove the proposed classification. On merits, drying, stripping and sprinkling raw tobacco with jaggery water did not amount to manufacture, since no new product with a distinct name, character or use emerged. The product was therefore treated as unmanufactured tobacco under CETH 2401 20 90, not chewing tobacco under CETH 2403 99 10.</description>
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