2014 (4) TMI 457

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....or the Respondent: Ms. Reena Khair, Adv. JUDGEMENT Per Ms. Archana Wadhwa: Being aggrieved with the order passed by Commissioner (Appeals), Revenue has filed the present appeal. We have heard Shri S. Jain, ld. DR appearing for the Revenue and Ms. Reena Khair, ld. advocate appearing for the respondents. 2. As per facts on record, respondents are engaged in the manufacture of MS tanks. T....

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....e the dish ends were required only for matching accuracy, they were tack welded. M/s ACC Machinery after receiving the goods have separated the dish ends from the tank which was further processed at their end. As such they pleaded that the dish ends is not a part of the tank so as to hold the tank as incomplete without the said dish ends. They also associated the proceedings on the point of limita....

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....move these dish ends. They undertake substantial internal fittings in the tank like fitting of air slides, channels agitating cloth etc. called internals and fitting of different valves outside the tank. Therefore dish ends are finally welded which results in the manufacture of bulkers. 7. The submissions made by the appellants have substance for the reason that if dish ends were to be used for....