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    <title>2003 (3) TMI 170 - CEGAT, MUMBAI</title>
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    <description>Processing plain M.S. plates into profiles, rings, circles, angles and channels was treated as manufacture because the resulting products were commercially distinct articles with a different shape, identity and use. The goods were also found marketable, as sale to customers against orders and payment was sufficient even without sale in the open market, making them dutiable. On classification, the processed goods were held to fall under sub-heading 7326.90 rather than 7208.11/7208.99. Concealment of the manufacturing activity and non-disclosure of material facts justified invocation of the extended limitation period, and the penalty was sustained.</description>
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      <title>2003 (3) TMI 170 - CEGAT, MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=51869</link>
      <description>Processing plain M.S. plates into profiles, rings, circles, angles and channels was treated as manufacture because the resulting products were commercially distinct articles with a different shape, identity and use. The goods were also found marketable, as sale to customers against orders and payment was sufficient even without sale in the open market, making them dutiable. On classification, the processed goods were held to fall under sub-heading 7326.90 rather than 7208.11/7208.99. Concealment of the manufacturing activity and non-disclosure of material facts justified invocation of the extended limitation period, and the penalty was sustained.</description>
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