Manufacture under excise law requires a new marketable product; mere dilution and repackaging of insecticide is not enough.

Dilution of concentrated alletherin by adding deodorized kerosene oil, perfume and a stabilising agent was held not to constitute manufacture under section 2(f) of the Central Excises and Salt Act. Manufacture does not cover every process or mere processing unless it results in a new substance known to the market; here, the insecticide was only weakened and repackaged, with no new product coming into existence. In the absence of any specific statutory note treating such dilution as manufacture, the activity fell outside section 2(f) and the question was answered against the Revenue.

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Issues: Whether dilution of concentrated alletherin by adding deodorized kerosene oil, perfume and stabilizing agent amounts to manufacture under section 2(f) of the Central Excises and Salt Act.

Analysis: Manufacture under section 2(f) does not extend to every process or to mere processing unless it results in a new substance known to the market. The concentrated insecticide was only diluted and repackaged in a weaker form; no new product came into existence. The process merely reduced potency and did not transform the raw material into a different commodity. In the absence of any specific statutory note treating such dilution as manufacture, the activity could not be brought within section 2(f).

Conclusion: The process did not amount to manufacture and the question was answered against the Revenue.

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