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1971 (8) TMI 195

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..... order of assessment related to sales of polishing compositions or polishing bars, which had all the shape of a bar soap, but according to the petitioner, did not have any intrinsic quality which is comparable to a soap as is popularly understood. The original assessing authority assessed it as an article which has to be taxed at the multi-point level the same not being provided for specifically i .....

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..... to metal polishing compositions. The petitioner produced the products manufactured by him and the learned Assistant Government Pleader had occasion to examine the same. For all outward purpose the shape of a big bar soap is maintained as regards the polishing compositions, but their utility is unique and bears no comparison to the ordinary and normal uses of a soap. The dictionary meaning of soap .....

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..... r section 16 of the Act appears to be not warranted in law. It is not a mere change of opinion which has prompted the assessing authority to reopen the assessment under section 16 of the Act, but the basis of revision appears to be that the later authority was of the view that the user to which the articles in question are normally put were misunderstood by the earlier authority. He explained thes .....

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..... the substitution or modification of the entry is stated to be that it was so made in order to make it clear that the metal polishing bars would fall under this item. This explanation by itself suggests that the position before the 1st of July, 1967, was not clear. If that were so, there was an ambiguity at or about, the time when the impugned order was passed, whether metal polishing bars or metal .....

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