Manufacture under Central Excise law was not established where decorative paper on hard board did not alter tariff classification.

Pasting decorative paper on hard board was treated as not amounting to manufacture under section 2(f) of the Central Excise Act, 1944, because the board continued to fall within the same tariff classification after the treatment. The chapter note and HSN guidance supported the view that classification did not change merely by covering the board with paper, and the claim that a distinct commercially known product emerged was not proved by traders' affidavits or expert evidence. The departmental challenge failed, and the lower appellate authority's order was sustained.

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Issues: Whether pasting decorative paper on hard board amounted to manufacture under section 2(f) of the Central Excise Act, 1944, and whether the goods ceased to remain classifiable under the same tariff heading.

Analysis: The board continued to fall within the same tariff classification even after being covered with paper, as the chapter note and the HSN guidance indicated that the classification did not change on such treatment. The revenue's assertion that a distinct commercially known product emerged was not substantiated by traders' affidavits or expert evidence.

Conclusion: The process did not establish manufacture for the purpose of duty, and the classification remained unchanged; the revenue's challenge failed.

Final Conclusion: The departmental appeal was rejected and the order of the lower appellate authority was sustained.

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