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    <title>2026 (4) TMI 1655 - CESTAT BANGALORE</title>
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    <description>Actual third-party sales established marketability despite FDG F-18&#039;s short shelf life, and the production process was therefore treated as manufacture of an excisable product. FDG F-18, being a radiopharmaceutical used for medical imaging and as a diagnostic reagent, was held classifiable under Chapter Heading 3006 3000 rather than Chapter Heading 2844 4000. The extended period of limitation was found unsustainable because the assessee acted under bona fide belief without suppression, and the valuation adopted for captive consumption and internal clearances was rejected for not following the proper reference to sales to independent buyers. The demand, penalty, confiscation, redemption fine, and impugned order were set aside.</description>
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      <description>Actual third-party sales established marketability despite FDG F-18&#039;s short shelf life, and the production process was therefore treated as manufacture of an excisable product. FDG F-18, being a radiopharmaceutical used for medical imaging and as a diagnostic reagent, was held classifiable under Chapter Heading 3006 3000 rather than Chapter Heading 2844 4000. The extended period of limitation was found unsustainable because the assessee acted under bona fide belief without suppression, and the valuation adopted for captive consumption and internal clearances was rejected for not following the proper reference to sales to independent buyers. The demand, penalty, confiscation, redemption fine, and impugned order were set aside.</description>
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