Relabelling imported cosmetics with statutory stickers does not amount to manufacture, so excise duty demand fails.

Pasting statutory stickers on imported cosmetics was treated as mere relabelling of goods already imported in fully packed form. The activity, done to comply with labelling requirements under the packaged commodities rules, did not amount to manufacture under Section 2(f) of the Central Excise Act, 1944 read with Chapter Note 4 of Chapter 33 of the Tariff. Prior Tribunal decisions had taken the same view, and the department's challenge to that position had already failed before the Apex Court. The resulting duty demand was therefore not sustainable.

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Issues: Whether pasting of stickers on imported cosmetics under Rule 33(4) of the Standards of Weights and Measures (Packaged Commodity) Rules, 1977 amounted to manufacture under Section 2(f) of the Central Excise Act, 1944 read with Chapter Note 4 of Chapter 33 of the Central Excise Tariff Schedule.

Analysis: The activity in question was only relabelling of goods already imported in fully packed form. The issue was treated as covered by earlier decisions holding that such relabelling, done to comply with statutory labelling requirements, did not amount to a process of manufacture and did not make the goods dutiable merely by reason of the sticker being pasted. The same view had been followed in subsequent Tribunal decisions and the department's challenge to the earlier Tribunal view had already failed before the Apex Court.

Conclusion: The activity of pasting statutory stickers on the imported goods did not amount to manufacture and the demand of duty was not sustainable.

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