Printing on customer-supplied material is not manufacture unless it creates a distinct marketable product.

Mere printing on customer-supplied cartons, sheets, labels and similar materials does not amount to manufacture for central excise purposes unless the process creates a new, marketable commodity with a distinct name, character or use, or is treated as manufacture by statute. The analysis focused on the absence of manufacturing infrastructure, raw material arrangement and any transformation into an independent excisable product. Tariff classification alone was said not to determine excisability. On that reasoning, the duty demand, interest and penalties could not be sustained, and the appeal succeeded in favour of the assessee.

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Issues: Whether the activity of printing on customer-supplied material, such as cartons, sheets, labels and allied products, amounts to manufacture so as to attract central excise duty.

Analysis: The activity was examined on the basis of the nature of the process undertaken and its effect on the identity of the goods. The record did not show that the appellants had the machinery, raw material arrangement, or manufacturing setup to produce excisable goods as such. Mere printing, without a statutory deeming provision, was found not to create a new and different article with a distinctive name, character or use. It was also not established that the printed goods were marketable as independent commodities, particularly since they were prepared for specific customers. The reasoning was consistent with prior tribunal decisions holding that printing by itself does not amount to manufacture and that tariff classification alone cannot determine excisability.

Conclusion: The activity of printing did not amount to manufacture and the duty demand, interest and penalties could not be sustained; the appeal succeeded in favour of the assessee.

Ratio Decidendi: Mere printing on material supplied for a specific customer does not amount to manufacture unless the process brings into existence a new, marketable commodity with a distinct name, character or use or is otherwise deemed manufacture by statute.

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