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2016 (11) TMI 312 - AT - Central ExciseManufacture - computer system assembled at the site of their clients from bought out items - limitation - penalty under Section 11AC - Held that:- On perusal of the records, we find that the demands raised with interest are in respect of the computer systems assembled at the site of customers. This activity is held as manufacturing by the Apex Court. On merits, the argument of the appellants is unacceptable to us that is not manufacturing computer system. On limitation, we find that appellant has a case in their favour, as against the very same impugned order, in Revenue’s appeal, the bench while dismissing the appeal, held that there is no fraud, collusion or suppression with intent to evade duty. Thus we hold that the impugned order is unsustainable only on the ground of limitation. - Decided in favour of assessee
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