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Refund of Special Additional Duty on Processed Cashew Nuts Approved; Same Tariff Heading for Nuts and Kernels.

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....Refund of SAD - cashew nut imported was subjected to processing and value addition which amounted to manufacture and the product had undergone change as to its identity - both cashew nuts and cashew kernels are classified as cashew nuts under CTH 0801. At the same time, it is not the case of Revenue that S.T./VAT/CST is different for cashew nuts and cashew kernel - Refund allowed.....