TMI Blog2002 (11) TMI 556X X X X Extracts X X X X X X X X Extracts X X X X ..... (T)]. - The appeals are against the order of the Commissioner demanding duty on what is found to be computer system manufactured by Compusoft and National Control Systems, and imposing penalties on these two firms and the partners Manoj Shah and Sushila Shah. 2. The counsel for the appellant limits his arguments to imposition of penalties, apart from the contention that penalties could not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ntal representative reiterates the finding of the Commissioner. 4. Since we are only concerned with the penalties imposed on the appellants, we refrain from expressing any view as to whether the activity undertaken by Compusoft and National Control Systems amounted to manufacture or not. So far as the penalty is concerned, we have seen the two decisions that have been cited before us, one holdin ..... X X X X Extracts X X X X X X X X Extracts X X X X
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