Packing of Parts Not Manufacturing Under Excise Until 2011 Amendment; No Extended Limitation Period for Tax.

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....Process amounting to manufacture or not - packing/re-packing of the parts/components - these items were not brought under the ambit of Section 2(f)(iii) fiction of manufacture - it was only brought in the Finance Act, 2011 with retrospective effect, at par with amendment to Notification issued u/s 4A - Extended period of limitation cannot be invoked.....