Printing on duty-paid plastic film is not manufacture where the film retains its identity and no new excisable commodity emerges.

Printing on duty-paid plain plastic film does not amount to manufacture where the film retains its basic identity and no distinct commercial commodity comes into existence. Applying Chapter Note 10 to Chapter 39 of the Central Excise Tariff and the settled test of whether a process creates a new product or destroys the original commodity's identity, the printed film was treated as plain plastic film in substance. The activity was therefore held not to give rise to a new excisable commodity liable to duty under Chapter 39.

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Issues: Whether printing on duty paid plain plastic film amounts to manufacture so as to create a new excisable commodity liable to duty under Chapter 39 of the Schedule to the Central Excise Tariff Act, 1985.

Analysis: The activity was examined in the light of Chapter Note 10 to Chapter 39 of the Schedule to the Central Excise Tariff Act, 1985 and the settled test whether a process brings into existence a different commercial commodity or whether the original commodity loses its identity and can no longer serve its intended purpose. The printed film remained plain plastic film in substance, and no new product came into existence merely because of printing. The reasoning was supported by the earlier view that printing on duty paid plastic film does not change its basic character into a distinct excisable commodity.

Conclusion: The printing of duty paid plain plastic film does not amount to manufacture.

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