Site-based installation of security systems is not manufacture where the finished system arises only at the customer's premises.

Installation and erection of duty-paid components at the customer's premises for fire alarm, burglar alarm, access control and CCTV systems did not amount to manufacture of excisable goods, because the integrated system came into existence only at the site. Relying on earlier Tribunal decisions and the Board order cited before it, the Tribunal treated the activity as part of construction and erection rather than manufacturing. The demand was therefore not sustainable, and the lower authority's order was set aside.

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Issues: Whether bringing duty-paid components to the customer's site and connecting them during installation of security systems amounts to manufacture of excisable goods.

Analysis: The components were assembled and installed at the customer's premises as part of the construction and erection process for fire alarm, burglar alarm, access control, and CCTV systems. The resulting systems came into existence only at the site and were treated as not constituting excisable goods in view of the Tribunal's earlier decisions and the Board's order relied upon by the Tribunal.

Conclusion: The activity did not amount to manufacture of an excisable product, and the demand could not be sustained.

Final Conclusion: The appeal succeeded and the lower authority's order was set aside.

Ratio Decidendi: A security system assembled and brought into existence only at the customer's site through installation and erection of duty-paid components is not manufacture of excisable goods.

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