Mere printing of plastic sheets does not constitute manufacture; duty recovery is limited to any unpaid duty on the plain sheets.

Mere printing of plain plastic sheets does not, by itself, amount to manufacture, so duty cannot be levied again merely because the sheets are printed after clearance. The earlier Supreme Court ruling in the assessee's own matter was applied for this principle. However, the record did not clearly establish whether duty had already been paid on the plain sheets before printing, so the factual position on pre-printing duty discharge required verification. The matter was therefore remanded to the original authority, and any recovery was confined only to unpaid duty, if any, on the plain plastic sheets at the pre-printing stage.

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Issues: Whether printing of plain plastic sheets amounts to manufacture and whether duty recovery could be sustained on the printed sheets or be confined to any unpaid duty on the plain sheets.

Analysis: The dispute turned on the correct character of the goods at two stages, namely plain plastic sheets cleared on duty and thereafter subjected to printing, as opposed to a single finished product treated as printed PVC sheets. The earlier Supreme Court ruling in the assessee's own matter was treated as holding that mere printing does not bring about manufacture and that duty cannot be levied again merely because the same product is printed, if the printing activity is the only subsequent process. At the same time, the factual position as to whether duty had already been discharged on the plain sheets was not clearly established on the record. On that basis, the matter required factual verification before the liability could be finally fixed.

Conclusion: The matter was remanded to the original authority, with recovery, if any, confined only to unpaid duty on plain plastic sheets manufactured before printing.

Ratio Decidendi: Mere printing of plastic sheets, by itself, does not constitute manufacture, and any duty recovery after such printing can extend only to duty that remained unpaid on the goods at the pre-printing stage.

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