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C.E. - Conversion of Anhydrous Ammonia into liquor Ammonia (AQueous solution of Ammonia) - Whether amounts to 'manufacture'- Regarding.

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....  Subject: C.E. - Conversion of Anhydrous Ammonia into liquor Ammonia (AQueous solution of Ammonia) - Whether amounts to 'manufacture'- Regarding. I am directed to say that doubts have been expressed as to whether conversion of duty paid Anhydrous ammonia into aqueous solution amounts to 'manufacture' within the meaning of section 2(f) of the Central Excise Act, 1944. 2. The t....

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...., Mumbai-III where the view taken was that this activity does not result in 'manufacture'. 4. The Board has taken note of the fact that (i) the activity is a simple one of dissolving ammonia in water under pressure for convenience of transportation. While transporting, at the despatch end, the ammonia is dissolved in water under pressure and at the receiving end the pressure is rem....

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....ook at the description appearing against heading 28.14 reveals that the heading supposes to cover the chemical viz. ammonia in either of the two forms anhydrous or in apueous solution. Heading 28.14 of CETA 85 is aligned to HSN, Chapter 28, which classifies both under different sub-headings. 7. Further, the usage of the punctuation mark "comma" in the heading description leads one to presu....

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....particular substance by any stretch of imagination could not be treated as a process amounting to manufacture. 8. It is further observed that all that is happening is that a method is being applied for transportation of the goods. There are many methods of transportation of goods. In the case of LPG for example, which is commonly used in house-holds, the gas is filled in the Cylinder under....