Fertiliser mixture

Department was not very keen on pursuing the question as to whether mixing of fertiliser amounts to manufacture for the reason that eventhough it amounts to manufacture the resultant goods stands exempted. But from 01-03-2011 fertilisers attracts duty @ 1%. Now the question can heat up because of the revenue impact and once it pops up , it can only be settled only at Supreme court  level. I feel that eventhough there is no chemical change takes place in mixing, the resultant product is commercially different from the point of view of the users and hence the possibility of same being held as amouning to manufacture cannot be rules out.
 

Thanks Mr Unni krishnan,

Kindly update me, in case of any development in the subject matter.  In fact, we have started paying the excise duty from 1.3.11 to avoid litigation.

rengaraj r.k