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    <title>2026 (5) TMI 1370 - CESTAT KOLKATA</title>
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    <description>Inputs cleared to job workers for conversion into PPCP containers were treated as processing for manufacture, not trading, because the record showed the granules were sent for conversion and then used in battery production. On that basis, reversal of Cenvat credit under Rule 3(5) was not required and the demand on the trading allegation could not be sustained. The extended limitation period was also unavailable because the clearances were disclosed in monthly returns and no suppression, wilful misstatement, or intent to evade duty was established. The demand was therefore unsustainable on merits and limitation, with the assessee granted full relief.</description>
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    <pubDate>Tue, 19 May 2026 00:00:00 +0530</pubDate>
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      <title>2026 (5) TMI 1370 - CESTAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=792168</link>
      <description>Inputs cleared to job workers for conversion into PPCP containers were treated as processing for manufacture, not trading, because the record showed the granules were sent for conversion and then used in battery production. On that basis, reversal of Cenvat credit under Rule 3(5) was not required and the demand on the trading allegation could not be sustained. The extended limitation period was also unavailable because the clearances were disclosed in monthly returns and no suppression, wilful misstatement, or intent to evade duty was established. The demand was therefore unsustainable on merits and limitation, with the assessee granted full relief.</description>
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