Manufacture includes printing and embossing on laminated PVC cloth, and fresh duty applies to the processed product.

Printing and embossing on laminated PVC leather cloth was treated as manufacture because the inclusive definition of manufacture covers processes incidental or ancillary to completion of a marketable finished product. The plain laminated fabric and the printed or embossed fabric were regarded as distinct marketable goods, so the further processing enhanced their value and marketability. Prior duty on the plain laminated fabric did not bar duty on the processed product, since the later item was separately identifiable despite falling under the same tariff entry. Fresh duty was therefore payable on the printed or embossed goods.

---

---

Issues: (i) Whether printing and embossing on laminated PVC leather cloth amounted to manufacture under Section 2(f) of the Central Excises & Salt Act, 1944. (ii) Whether duty could be levied again on the same tariff item after the plain laminated fabric had already suffered duty.

Issue (i): Whether printing and embossing on laminated PVC leather cloth amounted to manufacture under Section 2(f) of the Central Excises & Salt Act, 1944.

Analysis: The definition of manufacture is inclusive and extends to any process incidental or ancillary to the completion of a manufactured product. The plain laminated fabric and the printed or embossed fabric were treated as different marketable products, and the further processing enhanced the value and marketability of the goods. The specific sub-clauses relied upon by the assessee did not exclude the operation of the main part of the definition.

Conclusion: The process of printing and embossing constituted manufacture and was incidental or ancillary to completion of the finished product.

Issue (ii): Whether duty could be levied again on the same tariff item after the plain laminated fabric had already suffered duty.

Analysis: Prior duty payment on the base product did not preclude duty on the later, distinguishable product resulting from further processing. The existence of the same tariff entry was not decisive where the processed goods were separately identifiable and marketable. The earlier duty-paid character of the base material did not bar levy on the processed goods.

Conclusion: Fresh duty was payable on the printed or embossed product notwithstanding prior duty on the plain laminated fabric.

Final Conclusion: The appeal failed because the further printing and embossing process was held to be manufacture and the processed goods remained exigible to duty.

Ratio Decidendi: An inclusive definition of manufacture covers processes incidental or ancillary to completion of a marketable finished product, and prior duty on the base material does not prevent levy on a distinct, further-processed product.

---