Roasting of Rava/Suji: moisture reduction by single or double roasting held not to constitute manufacture, so no excise levy applies.

Whether subjecting plain rava/suji to single or double roasting constitutes 'manufacture' under the definition applicable to excise was contested; the process merely reduces moisture without producing a new commodity or altering physical character, use or marketability. The tribunal found that repeated roasting does not transform the product into a distinct article and therefore does not amount to manufacture, rejecting the revenue finding to the contrary. Consequentially, roasted rava/suji is not leviable to central excise as a manufactured food preparation and the impugned demand was set aside with relief to the appellant.

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Issues: Whether Rava/Suji subjected to single or double roasting (drying/heating reducing moisture) amounts to "manufacture" within the meaning of Section 2(f) of the Central Excise Act, 1944 and thereby becomes classifiable as a food preparation under Chapter Heading 1901 of the Central Excise Tariff Act, 1985.

Analysis: The product Rava/Suji is admitted to be a finished granular product classifiable under Chapter Heading 1103. The processes of drying and roasting described reduce moisture content (from about 14.5% to 11-12% for single roasting and to 6-8% for double roasting) without producing a new commodity or altering the essential character, physical properties or end-use of Rava/Suji. Application of the categorical tests used for determining "manufacture" distinguishes processes that merely remove foreign matter or effect minor changes from processes that transform goods into a new, marketable article. The roasting/drying here falls within the category where the article remains essentially the same and continues to be marketable as Rava/Suji; no value-adding transformation creating a distinct product sold in the market arises. Reliance on classification and explanatory notes for Chapter 11 supports that semolina/sooji falls under Heading 1103 and that roasting per se does not convert it into a Chapter 1901 "food preparation".

Conclusion: The process of single or double roasting/drying of Rava/Suji does not amount to "manufacture" under Section 2(f) of the Central Excise Act, 1944; therefore, the resultant product is not leviable to excise duty as a Chapter 1901 food preparation. Decision in favour of the assessee.

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