Slitting and packing of BOPP films do not amount to manufacture, following earlier Tribunal and Larger Bench guidance.

Slitting, winding and packing of BOPP films were examined to determine whether they constituted manufacture under Chapter 39. The Revenue argued, based on the HSN chapter note and explanatory notes, that the goods became marketable only after those processes. The Tribunal noted that the Commissioner (Appeals) had followed earlier Tribunal rulings on the same issue, including a Larger Bench view against the Revenue. The processes were held not to amount to manufacture, so the Revenue's appeal failed.

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Issues: Whether the processes of slitting, winding and packing of BOPP films amount to manufacture.

Analysis: The dispute turned on whether the processes carried out on BOPP films resulted in manufacture. The Revenue relied on the chapter note to Chapter 39 of the HSN and the explanatory notes to contend that the goods became marketable only after slitting, winding and packing. The Tribunal noted that the Commissioner (Appeals) had followed earlier decisions of the Tribunal on the same issue and also a Larger Bench decision holding against the Revenue.

Conclusion: The processes did not amount to manufacture and the Revenue's appeal failed.

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