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2005 (12) TMI 546 - ALLAHABAD HIGH COURTExtract: .......the very nature of the activity does not result in manufacture because no new commercial commodity comes into existence. In the result, both the revisions are allowed. Orders of Tribunal are set aside and it is held that fresh fruits and green vegetables in tinned container were not liable to tax under Notification No. 7038, dated January 31, 1985.
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