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2017 (7) TMI 55 - AT - Central ExciseManufacture - appellants received flats and angles of iron and steel supplied by M/s ABB Ltd. After cutting to size the said flats and angles and drilling holes therein, the said products were joined by using nuts, bolts and washers before returning the same to the principal namely M/s ABB Ltd. - whether the said process amounts to manufacture or not? - Held that: - The products, in question, as cleared by the appellants are specifically identifiable and classifiable under a tariff heading under Chapter 73. The raw materials are of general nature falling under Chapter 72. As such, we have no reason to interfere with the findings of the lower authorities, that the process amounts to manufacture - demand upheld. Extended period of limitation - Held that: - when the raw materials are supplied by principal/buyer they have not paid Central Excise duty for claimed to have paid service tax. In such situation, the appellants had knowledge and applied different reasoning to follow different tax liabilities for the same processes - extended period rightly invoked. Appeal dismissed - decided against appellant.
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