CE- Process of tinting of duty paid base white, etc. paint with duty paid stainer to obtain paint of different shades, whether amounts to manufacture - Clarification regarding.
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Tinting of duty-paid base paints not treated as manufacture, so no fresh excise liability on resultant shaded paint.
Tinting duty-paid base white emulsion/enamel paint with duty-paid stainers produces only a different shade without change in name, character or use; there are no Chapter or Section Notes treating tinting as manufacture. Applying the test that manufacture requires emergence of a new and different article, the Board holds tinting does not amount to manufacture and, where inputs are duty-paid, the resultant shaded paint does not attract fresh excise liability.