Wide manufacture definition includes cutting and packing for export, preserving exemption benefit under the central excise notification.

The wide definition of "manufacture" in Rule 13 of the Central Excise Rules, 1944 was held to cover cutting and packing undertaken for export goods as an "any other operation". On that basis, the assessee was entitled to the benefit of Notification No. 49/94-C.E. dated 22-9-1994, and the exemption could not be denied merely because the goods were subjected to those processes. The Tribunal followed earlier precedent treating such export-related cutting and packing as within the statutory expression and found no reason to depart from that view. The Revenue's challenge therefore failed, and the benefit granted to the exporter was affirmed.

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Issues: Whether the process of cutting and packing undertaken for export goods falls within the expression "any other operation" in Rule 13 of the Central Excise Rules, 1944 so as to entitle the assessee to the benefit of Notification No. 49/94-C.E. dated 22-9-1994.

Analysis: The dispute turned on the scope of the definition of "manufacture" in Rule 13 of the Central Excise Rules, 1944. The Tribunal treated the question as already settled by earlier decisions holding that the definition has very wide coverage and that cutting and packing for export is covered by "any other operation". The Tribunal followed its earlier view and the connected precedent relied upon therein, and saw no reason to differ from that line of authority.

Conclusion: The process of cutting and packing qualified as an eligible operation under Rule 13 and the assessee was entitled to the benefit of Notification No. 49/94-C.E. dated 22-9-1994.

Final Conclusion: The Revenue's challenge failed and the order granting the notification benefit to the exporter was affirmed.

Ratio Decidendi: Where the statutory definition of manufacture under Rule 13 is wide enough to include cutting and packing for export as "any other operation", the exemption benefit under the notification cannot be denied on that ground.

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