2024 (7) TMI 264

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..... parlance and it is a different product from MS and HSD - CBEC Circular No.139/08/2000-CX-4 dated 03.01.2001 - HELD THAT:- In respondent s own case this Tribunal entertained the issue M/S. I.O.C. LTD. VERSUS COMMISSIONER OF CENTRAL EXCISE, PATNA [ 2019 (4) TMI 1072 - CESTAT KOLKATA ] and held that the process or treatment to enhance the marketability of a product or to improve the value addition d .....

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..... and HSD from its refinery division and mixed the same with MFA in a particular proportion which resulted in emergence of new products namely, Xtra Premium and Xtra Mile. Revenue is of the view that such process of mixing and blending makes a new product which is marketable in commercial parlance and it is a different product from MS and HSD, therefore the respondent has manufactured a new product .....

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..... ent s own case this Tribunal entertained the issue as reported in 2019 (368) ELT 146(Tri.- Kolkata and held that the process or treatment to enhance the marketability of a product or to improve the value addition does not amount to manufacture relying on the Tribunal s decision in Hindustan Petroleum Corporation Ltd. v. CCE, Delhi Rohtak as reported in 2009 (234) E.L.T. 648. The said order of this .....

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