Manufacture through photo book printing and binding brings a distinct product within Chapter 4911, excluding service tax.

Printing photographs on plain paper, laminating and binding them into photo books or photo albums was treated as manufacture because the process created a new commercially distinct product with a different name, character and end use. The activity was held classifiable under Chapter 4911, supported by the tariff position and CBIC/TRU clarification that such goods fall under HS Code 4911. On that basis, and in view of the exemption notifications covering printing activity and printing as job work, service tax was held not payable on the activity.

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Issues: Whether the activity of printing, binding and sale of photo books/photo albums amounts to manufacture and falls under Chapter 4911, so that service tax is not payable.

Analysis: The activity was found to involve printing photographs on plain printing paper, laminating and binding them into photo books, resulting in a distinct product with a different identity, character and end use. The reasoning applied the settled test that a process amounts to manufacture when it brings into existence a new commercially distinct article having its own name, character or use. The conclusion was reinforced by the tariff classification under Chapter 4911, the CBIC/TRU clarification that such goods fall under HS Code 4911 and attract GST, and the service tax exemption notifications covering printing activity and printing as job work.

Conclusion: The activity amounts to manufacture, is classifiable under Chapter 4911, and no service tax is payable.

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