Assembling purchased computer parts is not manufacture when only market-bought components are put together into a system.

Assembling purchased computer parts and peripherals into a computer system was treated as not amounting to manufacture under Heading 8471000, because the activity involved only putting together market-bought components without bringing about a new product in the legal sense. The analysis relied on settled Tribunal and Supreme Court authority, and no distinguishing feature was shown to justify departure from that view. On that basis, the duty demand and connected adverse order could not survive, and the activity was considered outside the scope of manufacture for central excise purposes.

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Issues: Whether assembling purchased computer parts and peripherals in the assessee's premises into a computer system amounts to manufacture under heading 8471000 of the Central Excise Tariff Act, 1985.

Analysis: The Tribunal followed its earlier decision and the settled view that merely buying various computer parts from the market, assembling them, and supplying them as a computer system does not, by itself, amount to manufacture. The issue had already been treated as settled by prior Tribunal and Supreme Court decisions, and no distinguishing feature was shown to justify a different view. On that basis, the demand of duty and the connected adverse order could not survive.

Conclusion: The activity did not amount to manufacture, and the impugned order was set aside in favour of the assessee.

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