https://www.taxtmi.com/caselaws?id=52531 The extended period of limitation was unavailable because the units pre-existed the later notification changes and the record did not show deliberate fragmentation or suppression to evade duty; the demand was therefore time-barred. Bleaching, mercerising, calendering, stentering and squeezing of excess water, as found on the facts, did not amount to manufacture in the manner alleged, so no duty liability arose on that basis. The proviso to Notification No. 253/82-C.E. was held to operate factory-wise, with the decisive test being the identity of the premises rather than common management or related interests; the exemption could not be denied merely because the units were commercially linked. The Revenue's appeals failed and the assessees retained the exemption. en-us Tue, 30 Dec 2003 00:00:00 +0530 Wed, 06 Oct 2010 13:19:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=52531 The extended period of limitation was unavailable because the units pre-existed the later notification changes and the record did not show deliberate fragmentation or suppression to evade duty; the demand was therefore time-barred. Bleaching, mercerising, calendering, stentering and squeezing of excess water, as found on the facts, did not amount to manufacture in the manner alleged, so no duty liability arose on that basis. The proviso to Notification No. 253/82-C.E. was held to operate factory-wise, with the decisive test being the identity of the premises rather than common management or related interests; the exemption could not be denied merely because the units were commercially linked. The Revenue's appeals failed and the assessees retained the exemption. Case-Laws Central Excise Tue, 30 Dec 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=52531