relevant portion

Blending of tea for export by an industrial unit in SEZ area is a manufacturing activity which qualifies for exemption u/s 10A/10AA

The short question that arises for consideration is whether blending and packing of tea for export in the industrial unit in the Special Economic Zone amount to manufacture or production of an article qualifying for exemption under Section 10A of the Act, that is, during the period prior to introduction of "blending" as "manufacture" with effect from 10.2.2006.
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Rajesh Kumar Sharma V. UOI [2007 (209) ELT 3 (SC)] (Miscarriage of justice)

The petitioner was being prosecuted for an offence under Customs Act for the last 12 years. The value of the offending goods was Rs. Eight lakhs (approx). 20% of the value of goods comes out to be approx 1.6 lakhs. The compounding authority comes to the conclusion that out of 1.6 lakhs and 10 lakhs, 10 lakhs is higher and hence imposed a compounding amount of Rs. 10 lakhs.
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