TMI Blog2004 (2) TMI 86X X X X Extracts X X X X X X X X Extracts X X X X ..... ure." 2.The applicant is a resident company registered under the Companies Act, 1956 and proposes to set up a joint venture in India in collaboration with a non-resident, viz. M/s. H.R. International, an independent company registered in Belgium. The applicant would be purchasing high security vehicle registration number plates from manufacturers. It would then manufacture aluminium sheets in coil form which would be flattened and laminated with retro reflective sheets. Thereafter chrome hologram shall be stamped with the hologram hot stamping machine. Thus, various sizes of licence plates would be manufactured; each plate will be having a unique serial number braided on each plate with a laser braiding machine which is a security featur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ld not be rejected and submits that he waives issuance of a written notice and would argue the point regarding the maintainability of the application. Heard also the learned Departmental Representative. 5.It would be useful to read Section 23C of the Act here. "Section 23C. Application for advance ruling. - (1) An applicant desirous of obtaining an advance ruling under this Chapter may make an application in such form and in such manner as may be prescribed, stating the question on which the advance ruling is sought. 2. The question on which the advance ruling is sought shall be in respect of, - (a) classification of any goods under the Central Excise Tariff Act, 1985 (5 of 1986); (b) applicability of notifi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... relation to an activity proposed to be undertaken, by the applicant;" The expression "advance ruling" means the determination of a question of law or fact regarding the liability to pay duty in relation to an activity proposed to be undertaken by the applicant. The term 'activity' is defined in Clause (a) of Section 23A to mean production or manufacture of goods. The expression does not postulate determination of a question as to whether the process leading to production of excisable goods amounts to activity or manufacture within the meaning of the Act. In our considered view, the definition of the said expression which, cannot be read in isolation, has to be harmoniously interpreted with the provisions of sub-section (2) of Section 23 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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