Manufacture for central excise requires transformation into a...

Manufacture for central excise requires transformation into a new, distinct and marketable commodity with a separate name, character and use; labour, skill, expense or value addition alone does not suffice. Kitting imported photocopier modules by unpacking and placing them into customer-specific sets was not manufacture where the components remained in original packing, no physical assembly occurred at the warehouse, and relevant fittings had been made abroad. Note 6 to Section XVI could not deem manufacture because the modules were imported and assessed as complete machines, with no subsequent conversion of incomplete goods into complete articles. Rule 2(a) governs classification only and does not determine manufacture. The excise-duty demand was unsustainable.