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2018 (2) TMI 1559 - AT - Central ExciseManufacture - business and trading of perforated sheets and wire netting - Department came to the conclusion that the activity of perforation of flat rolled steel sheets procured from the open market would amount to manufacture in terms of Section 2(f) of the CEA 1944 - Held that: - the Hon’ble Allahabad High Court in the case of Agra Metal Perforators vs. Commissioner, Sales Tax [1980 (7) TMI 242 - ALLAHABAD HIGH COURT] has expressed the clear opinion that after perforation, the iron sheet emerges as a different commercial commodity - the activity of perforation of flat rolled steel sheets does amount to manufacture. Extended period of limitation - Held that: - there can be no justification for invoking the extended period of limitation under Section 4A for demand of such duty - demand restricted to normal period. Appeal allowed in part.
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