Affixing retail price stickers on imported goods for local compliance was treated as not amounting to manufacture for pre-deposit relief.

Affixing retail price stickers on imported goods to comply with local legal requirements did not, on the available material, by itself amount to manufacture. The Tribunal also noted that the same product had earlier been classified under the relevant tariff sub-heading and that departmental clarification supported the view that sticker pasting for compliance purposes is not manufacture. On that basis, the appellants established a prima facie case, and pre-deposit was waived pending regular hearing. The merits of the classification and manufacture dispute were left open for final adjudication.

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Issues: Whether the appellants were required to make pre-deposit in a case where affixing retail price stickers on imported goods was alleged to amount to manufacture, and the goods were also disputed on classification.

Analysis: The imported bathing bars had already suffered customs and additional customs duty at the time of import. The only subsequent activity was affixing labels showing the retail price to comply with local law. The Tribunal noted that in the appellant's own earlier case, the same product had been classified under sub-heading 3401.20, and the Board had clarified that pasting stickers on imported goods for compliance with local law would not amount to manufacture. On that basis, the Tribunal held that the appellants had made out a prima facie case for interim relief.

Conclusion: The requirement of pre-deposit was waived and the matter was directed to be listed for regular hearing.

Final Conclusion: Interim relief was granted in favour of the appellants, and the dispute on merits was left open for regular adjudication.

Ratio Decidendi: Affixing a price sticker on imported goods to comply with local legal requirements does not, by itself, constitute manufacture for the purpose of interim pre-deposit relief where a prima facie case is otherwise shown.

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