Repacking and labelling of gums and pastes was not manufacture, so no central excise duty arose on the process.

Repacking gums and pastes from bulk packs into smaller containers, followed by affixing labels, did not amount to manufacture under central excise law where the goods were purchased in bulk from another manufacturer and the record did not show that repacking was necessary to make them saleable. In the absence of any tariff note treating such activity as manufacture for the relevant goods, the process was held insufficient to create a dutiable manufactured product, and the duty demand was not sustainable.

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Issues: Whether repacking of gums and pastes into smaller containers and affixing a label amounted to manufacture so as to attract central excise duty.

Analysis: The goods were found to have been purchased in bulk from another manufacturer, and the record did not support the claim that they could not be sold without repacking and labelling. On that finding, mere repacking and affixing of labels did not satisfy the definition of manufacture under the central excise law, and there was no tariff note treating such activity as manufacture for the relevant goods.

Conclusion: Repacking and labelling did not amount to manufacture, and the duty demand was not sustainable.

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