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The SC dismissed the appellant's appeal, holding that the process of enclosing the imported genset in a steel container and integrating radiator, fan, filters, tank, pipes, pumps, valves and silencer effects a qualitative transformation such that a new, distinct and marketable commodity (the "Power Pack") emerges. Applying the transformation and marketability tests, the Court found the final product possesses a different character, structure and functional utility (portability) from the imported genset, and is marketed to end customers. The activity therefore constitutes "manufacture" under Section 2(f)(i) of the Act, and the appellant is liable to pay excise duty on the goods manufactured.
The SC dismissed the appellant's appeal, holding that the process of enclosing the imported genset in a steel container and integrating radiator, fan, filters, tank, pipes, pumps, valves and silencer effects a qualitative transformation such that a new, distinct and marketable commodity (the "Power Pack") emerges. Applying the transformation and marketability tests, the Court found the final product possesses a different character, structure and functional utility (portability) from the imported genset, and is marketed to end customers. The activity therefore constitutes "manufacture" under Section 2(f)(i) of the Act, and the appellant is liable to pay excise duty on the goods manufactured.
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