Labelling and relabelling threshold under excise law excludes a compliance sticker that merely shows importer details and MRP.

Affixing a sticker on imported soap packets showing the importer's name and MRP, when done only to comply with weights and measures requirements, did not amount to labelling or relabelling under Note 6 to Chapter 34. The deeming provision applies where there is replacement or pasting over an existing label, repacking from bulk to retail packs, or another treatment that renders the product marketable. Because the sticker merely added required information and did not cover or replace any existing label, the activity was not treated as manufacture. The Revenue's challenge failed and the impugned order was sustained.

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Issues: Whether affixing a sticker on imported soap packets, containing the importer's name and MRP, amounts to labelling or relabelling so as to constitute manufacture under Note 6 to Chapter 34 of the Central Excise Tariff Act, 1985.

Analysis: Note 6 to Chapter 34 deems manufacture only where there is labelling or relabelling of containers, repacking from bulk packs to retail packs, or any other treatment rendering the product marketable. The sticker placed on the imported soap packets only conveyed the importer's name and MRP to satisfy the requirements under the weights and measures law. It did not replace an existing label, nor was any label pasted over another label. On that basis, the activity was not the kind of labelling or relabelling contemplated by the deeming provision. The Board's view in a comparable context of imported medicines was also treated as supporting the same interpretation.

Conclusion: Mere affixing of such a sticker did not amount to labelling or relabelling and therefore did not amount to manufacture. The appeal of the Revenue failed.

Final Conclusion: The impugned order was sustained and the Revenue's challenge was rejected.

Ratio Decidendi: A sticker added only to disclose importer details and MRP, without replacing or covering an existing label, does not constitute labelling or relabelling within a deeming provision treating such processes as manufacture.

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