TMI Blog2015 (3) TMI 382X X X X Extracts X X X X X X X X Extracts X X X X ..... into required shapes and sizes such as annular foam ring, rounds and squares as required by the customers. Merely cutting a sheet or film into required shape of size does not result in bringing into existence any new product and therefore, there is merit in the contention of the respondent that the activity undertaken by them did not amount to "manufacture". The lower appellate authority has also ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ivalent amount of penalty on the ground of limitation and also on the ground that the activity undertaken by the appellant does not amount to manufacture . Aggrieved of the same, the Revenue is before us. 3. In the appeal memorandum, it is submitted that the respondent herein, M/s. Universal Enterprises undertook cutting to shape of plastic firms and sheets as per customer's requirements a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sides. 6.1 The activity undertaken by the appellant is cutting of plastic sheets/films purchased from the market into required shapes and sizes such as annular foam ring, rounds and squares as required by the customers. Merely cutting a sheet or film into required shape of size does not result in bringing into existence any new product and therefore, there is merit in the contention of the res ..... X X X X Extracts X X X X X X X X Extracts X X X X
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