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    <title>2026 (6) TMI 1101 - CESTAT BANGALORE</title>
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    <description>Melting bullion into bars, coins, medals and medallions was held to amount to manufacture because the process produced goods with a distinct commercial identity and use; the activity was therefore not mere trading. Gold bars of 10/20/50 grams were treated as primary gold and exempt under Notification No. 12/2012-CE, while gold and silver coins fell under heading 7114 but remained exempt under the same notification. Medals, medallions and gift items were classified under heading 7114 and attracted duty for the normal period. As the record did not show wilful suppression, fraud or intent to evade duty, the extended limitation period and penalties were not sustainable.</description>
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      <link>https://www.taxtmi.com/caselaws?id=793720</link>
      <description>Melting bullion into bars, coins, medals and medallions was held to amount to manufacture because the process produced goods with a distinct commercial identity and use; the activity was therefore not mere trading. Gold bars of 10/20/50 grams were treated as primary gold and exempt under Notification No. 12/2012-CE, while gold and silver coins fell under heading 7114 but remained exempt under the same notification. Medals, medallions and gift items were classified under heading 7114 and attracted duty for the normal period. As the record did not show wilful suppression, fraud or intent to evade duty, the extended limitation period and penalties were not sustainable.</description>
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