Goods under Notification No.10/1997 are not exempt; Rule 6(3) of Cenvat Credit Rules is inapplicable.

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....CENVAT Credit - exempt goods - On merits, it is a case that the appellant is manufacturing dutiable goods not exempted goods. Some clearances were exempted from payment of duty by way of Notification No.10/1997 dt.1.3.1997, (amended) to specified buyer of the goods if those buyers fulfil condition of the said notification. Buying goods from the appellant under Notification No.10/1997 dt.1.3.1997 without payment of duty does not change the character of the goods as exempted goods - Rule 6(3) of Cenvat Credit Rules are not applicable to the facts of the present case. - AT....