Mere repacking of maize starch is not manufacture when the goods retain their identity for excise duty purposes.

Mere sieving, sifting, labelling and repacking of duty-paid maize starch into smaller packs does not amount to manufacture under excise law when the identity and character of the goods remain unchanged. The Tribunal held that no new product emerged from the packing process, and the fact that smaller packs fetched a higher price did not create excisability. On that basis, the goods were not liable to central excise duty, and the order in favour of the assessee was upheld.

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Issues: Whether sieving, sifting, labelling and repacking maize starch into smaller packs amounts to manufacture so as to attract central excise duty.

Analysis: The Tribunal followed its earlier decisions holding that mere sieving, labelling and packing into smaller packs does not bring about a new product or a manufacture within the meaning of the excise law. Charging a higher price for smaller packs did not alter the character of the goods or create excisability, since no manufacturing activity had taken place.

Conclusion: The process undertaken by the assessee did not amount to manufacture and the goods were not liable to duty on that basis.

Final Conclusion: The revenue appeal failed and the order in favour of the assessee was upheld.

Ratio Decidendi: Mere sieving, labelling and repacking of duty-paid maize starch into smaller packs, without any change in the identity of the goods, does not constitute manufacture for excise purposes.

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