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    <title>2004 (8) TMI 189 - CESTAT, NEW DELHI</title>
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    <description>Testing, purification, grading and certification of purchased helium gas cylinders were held to amount to manufacture because the process converted a generic marketable product into commercially distinct grades with different properties and market value. The activity was treated as more than mere handling or relabelling, and the contrary view of the Commissioner (Appeals) was rejected. On limitation, suppression was established because the assessee did not disclose the process or pay duty from the first clearance, so the extended period applied and the demand was not time-barred. The demand, penalty and interest were restored.</description>
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      <description>Testing, purification, grading and certification of purchased helium gas cylinders were held to amount to manufacture because the process converted a generic marketable product into commercially distinct grades with different properties and market value. The activity was treated as more than mere handling or relabelling, and the contrary view of the Commissioner (Appeals) was rejected. On limitation, suppression was established because the assessee did not disclose the process or pay duty from the first clearance, so the extended period applied and the demand was not time-barred. The demand, penalty and interest were restored.</description>
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