Sticker affixation on imported potato chips was not manufacture; duty demand failed under the tariff notes.

Affixing stickers on imported potato chips to display importer details, MRP, packing date, brand mark, net weight and last date of use did not amount to manufacture under the tariff notes. The process was undertaken only to comply with package commodity requirements and did not alter the original product or its essential character. A mere sticker, without more, was held insufficient to constitute labelling or relabelling for the deeming provision. The duty demand was therefore not sustainable.

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Issues: Whether affixing stickers on imported potato chips, containing particulars such as importer details, MRP, packing date, brand mark, net weight, and last date of use, amounted to manufacture under the relevant tariff notes.

Analysis: The goods were imported and only stickers were pasted to comply with package commodity requirements. The process did not alter the original product or its essential character. A mere sticker, without more, does not amount to labelling or relabelling so as to attract the deeming provision of manufacture under the tariff notes.

Conclusion: The process undertaken by the importer did not amount to manufacture, and the duty demand was not sustainable.

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