Documentary evidence prevails over admission where bought-out goods and assembled parts do not amount to manufacture of computers.

Consistent documentary evidence showed that the goods were bought-out computers and related materials, not computers manufactured by the appellant, so central excise duty and registration could not be sustained on a manufacture theory. The JCL 6000 data station was treated as a component or part of a computer, not a computer itself, and the Department produced no reliable material to disprove the appellant's records. A partner's statement that the firm manufactured computers was not treated as conclusive where it conflicted with undisputed bills and supporting purchase and supply details. The finding of manufacture was therefore set aside.

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Issues: Whether the appellant was manufacturing computers so as to attract central excise duty and the requirement of registration, or whether the goods cleared were merely bought-out items and assembled data stations not amounting to manufacture of computers.

Analysis: The documentary record showed that the appellant had purchased computers and related materials from the market, and the bills relied upon by the adjudicating authority were not disputed by the Department. The JCL 6000 data station consisted of software, interface cards and a manual kit, and was treated as a component or part of a computer rather than a computer itself. The appellant's purchases and subsequent supply of computers from the market were supported by bills and other details accepted at the adjudication stage. In these circumstances, the statement of a partner that the firm manufactured computers was not treated as conclusive, particularly when it was inconsistent with the documentary evidence and the Department produced no reliable material to disprove the appellant's case.

Conclusion: The finding that the appellant was manufacturing computers was set aside, and the appellant was held not liable on that basis.

Ratio Decidendi: A mere admission cannot prevail over consistent documentary evidence showing that the disputed goods were bought-out items and that the activity undertaken did not amount to manufacture of the alleged excisable product.

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