Manufacture under Central Excise was left open as repacking and labelling of garments needed fresh factual determination.

Activities involving repacking imported ready-made garments, affixing brand-related labels and barcodes, and related treatment were examined for possible manufacture under Section 2(f) of the Central Excise Act read with Note 4 of Chapter 62. The analysis stresses that manufacture, as a charging concept, requires strict construction and that an incidental or ancillary process is not enough unless it brings about manufacture in law. Because the record lacked clear findings on the processes carried out, including work done at job workers' premises and the assessee's own premises, the applicability of the chapter note and the resulting duty liability required fresh determination. The matter was therefore remanded for de novo consideration.

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Issues: Whether the activities of repacking imported ready-made garments, affixing brand-related labels and barcodes, and carrying out related treatment amounted to manufacture under Section 2(f) of the Central Excise Act, 1944 read with Note 4 of Chapter 62 of the Central Excise Tariff Act, 1985, and whether the matter required remand for fresh findings on the factual and legal aspects.

Analysis: Section 2(f) was examined in conjunction with Chapter Note 4, and the distinction between an incidental or ancillary process and a process that itself brings about manufacture was emphasized. The definition of manufacture, being a charging provision, was treated as requiring strict construction. The record did not contain a finding on whether the activities in question, particularly those performed at job workers' premises and the nature of the actual processes undertaken in the assessee's premises, satisfied the legal test. The factual matrix and the applicability of the chapter note therefore required fresh determination, along with the consequent quantification of duty and related liability.

Conclusion: The issue was not finally decided on merits; the order was set aside and the matter was remanded for de novo consideration of manufacture, duty liability, and connected consequences.

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