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2007 (7) TMI 135

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....ed in this appeal is as to whether repair of transformer would amount to manufacture. 2.The facts of the case in brief are that the respondents are engaged in the manufacture of Power Distribution Transformers classified under sub­heading 8504.00 of the CETA 1985. They are also undertaking repairing job of transformers supplied by the various State Electricity Boards on the basis of the con....

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....being filed by the Revenue. 3.Heard both sides and perused the record. 4.It is the contention of the ld. Departmental Representative that in this case the damaged transformers were completely dismantled in the premises of the State Electricity Board and two parts i.e. Core and Tank were handed over to the parties. We find that the Commissioner (Appeals) examined the issue in detail. The rele....

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.... under heading 3. replacement of parts :- This will involve removal of damaged/defective parts, supply of new parts such as — wherever necessary. This clause shows that only defective parts of transformer were to be replaced. The above points show that the parties were receiving core and tanks with some other parts as subassemblies and not as understood in the layman language of Tank and Core." ....