Commercial identity test affirms transformer parts classification; departmental knowledge bars extended limitation and demand is set aside.
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....Classification dispute concerned MS tanks, frames and gland plates: applying the commercial identity test and purchaser-supplied drawings and certificates, the tribunal concluded these items are parts of electrical transformers and correctly classifiable under CTH 85049010; contemporaneous ER-1 returns and departmental knowledge of clearances precluded invocation of the extended period of limitation, so the demand was set aside and impugned order quashed with consequential relief.....
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