TMI Blog2015 (2) TMI 182X X X X Extracts X X X X X X X X Extracts X X X X ..... finished goods can be produced since finished goods exhibits altogether a different look quite distinct from raw material which is visible to naked eye. It may be stated that there was structural change by touch when finished goods derived from the raw material is examined. It is also established that the appellant did not prefer to sell the raw material but sold finished goods undertaking proces ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... goods. Those goods are exhibited today for examination by the Bench as well as Revenue. 2. By an apparent look, the raw material suggests that without undertaking processing thereof no finished goods can be produced since finished goods exhibits altogether a different look quite distinct from raw material which is visible to naked eye. It may be stated that there was structural change by touch ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pellant amounts to manufacture which gave rise to the finished goods which was liable to excise duty. Accordingly, duty shall be payable at appropriate rate prevailing at the relevant period and interest to follow. 5. For the difficulty of interpretation of law and technicality of examination involved, penalty imposed is waived. 6. Appeal is partly allowed to the extent indicated above. ( ..... X X X X Extracts X X X X X X X X Extracts X X X X
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