TMI Blog2014 (1) TMI 1163X X X X Extracts X X X X X X X X Extracts X X X X ..... on, may not be held to be manufacturing activity - instead of first mixing the various masalas, masalas could have also been used directly on the final product - It is for the sake of convenience practicability and uniformity of taste that masalas are first mixed and then sprinkled - with the transfer of such interim product to the appellant’s own factory located elsewhere does not reflect the mar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rket in ready to use condition. However, before sprinkling the various masalas on the said goods, they are mixed together so as to attain uniformity in taste. They also mix some other ingredients like Diluents, Food Colourings, Synergetics Salt, etc before using the said mixed Masala on the Namkeens and Potato Chips. 2. In as much as the appellants final product is exempt from payment of duty, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... R for the respondents stated that the appellants themselves were classifying the product under Chapter 21 and that withdrawal of Exemption Notification providing exemption to products of said Chapters, the appellant shifted their product classficiation to Chapter 9 which continued to be under nil tariff rate. As such, he submits that even the appellants themselves were holding the product to be ma ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nts for captive consumption, may not be held to be manufacturing activity. During the course of hearing, it was clarified that instead of first mixing the various masalas, masalas could have also been used directly on the final product. It is for the sake of convenience practicability and uniformity of taste that masalas are first mixed and then sprinkled. We find prima facie force in the above co ..... X X X X Extracts X X X X X X X X Extracts X X X X
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