Assembly of duty-paid components into video cassettes was not manufacture under excise law, as earlier precedent controlled the result.

Assembly of duty-paid video magnetic tapes in pancake form and separately assessed plastic casings into video cassettes did not amount to manufacture under Section 2(f) of the Central Excise Act. The Tribunal applied an earlier decision on similar assembly activity and distinguished the Revenue's cited cases as factually different, leading to rejection of the Revenue's appeal.

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Issues: Whether assembly of duty-paid video magnetic tapes and plastic casings into video cassettes amounted to manufacture within the meaning of Section 2(f) of the Central Excise Act.

Analysis: The Tribunal found that the goods used by the assessee were duty-paid video magnetic tapes in pancake form and plastic covers, which were separately assessed and then assembled in the factory. It held that the earlier decision concerning similar assembly of such components governed the present facts, and that the cases cited by the Revenue did not alter the position because they dealt with different factual situations.

Conclusion: The activity did not amount to manufacture under Section 2(f) of the Central Excise Act, and the Revenue's appeal failed.

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