Stickering imported goods with importer details and MRP does not amount to deemed manufacture under tariff notes.

Mere pasting of a sticker showing the importer's name and retail sale price on imported goods does not amount to manufacture under the deemed manufacture provisions in the tariff notes. The process was limited to compliance with the packaged commodities regime, with no replacement of the original labels and no fresh label affixed over an existing one. Because the goods were already imported and marketable before the sticker was added, the activity did not transform them into a different product or make otherwise unmarketable goods marketable. The Revenue's demand therefore fails.

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Issues: Whether affixing stickers containing the importer's name and MRP on imported goods amounts to manufacture under the relevant tariff notes.

Analysis: The process undertaken was limited to pasting a sticker showing the name of the importer and the retail sale price as required under the packaged commodities regime. The original labels were not replaced and no fresh label was affixed over an existing label. The goods were already imported and marketable before the sticker was added, so the process did not bring about a transformation that would attract the deemed manufacture provisions in the tariff notes.

Conclusion: Mere affixing of stickers in the manner described does not amount to manufacture by labelling or re-labelling, and the Revenue's demand fails.

Ratio Decidendi: Mere pasting of a sticker to display importer details and MRP, without replacement or alteration of existing labels and without making otherwise unmarketable goods marketable, does not constitute manufacture under the deemed manufacture provisions.

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