Affixing holograms on pre-packed medicines is not manufacture where there is no relabelling or value addition.

Affixing holograms and barcodes on pre-packed, duty-paid medicines and placing them in an outer cover for transport did not amount to manufacture under the relevant chapter notes. The Court relied on the Board circular that mere transfer of pre-packed retail goods into another packing, without relabelling, alteration of the retail pack, or value addition, does not attract central excise duty. As the activity was only for anti-duplication and safe carriage, the Tribunal's view was upheld, the excise demand failed, and no substantial question of law was found to arise.

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Issues: Whether affixing holograms and barcodes on pre-packed duty-paid medicines and placing them in an outer cover amounted to manufacture so as to attract central excise duty, and whether any substantial question of law arose for consideration.

Analysis: The goods were received by the assessee in a pre-packed, duty-paid form with the retail price already declared. The only activity undertaken was affixing holograms and barcodes to prevent duplication and placing the goods in an outer cover for safe transportation. The Court applied the Board circular clarifying that where pre-packed duty-paid retail goods are merely transferred into another packing without relabelling, alteration of the retail pack, or any value addition, excise duty is not attracted. Since the activity did not amount to any process of manufacture under the relevant chapter notes and there was no value addition, the Tribunal's view was held to be justified.

Conclusion: The activity did not amount to manufacture and the excise demand could not be sustained. The appeal was dismissed as no substantial question of law arose.

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