https://www.taxtmi.com/caselaws?id=72982 Packing of loose tea can amount to manufacture for excise purposes, and package tea falls under Tariff Item 3(2). The manufacturer is the person who actually undertakes the packing work on a genuine principal-to-principal basis, unless the arrangement is proved to be a dummy or camouflage for the loose tea supplier. Where the packer has its own licensing arrangement, performs the work for consideration, and receives labour, input, profit, and transport charges under a real commercial contract, the packer is treated as the manufacturer. In that situation, concessional benefit under Notification No. 198/76-CE is available and differential duty is not sustainable. en-us Tue, 26 May 1987 00:00:00 +0530 Thu, 26 May 2011 13:04:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=72982 Packing of loose tea can amount to manufacture for excise purposes, and package tea falls under Tariff Item 3(2). The manufacturer is the person who actually undertakes the packing work on a genuine principal-to-principal basis, unless the arrangement is proved to be a dummy or camouflage for the loose tea supplier. Where the packer has its own licensing arrangement, performs the work for consideration, and receives labour, input, profit, and transport charges under a real commercial contract, the packer is treated as the manufacturer. In that situation, concessional benefit under Notification No. 198/76-CE is available and differential duty is not sustainable. Case-Laws Central Excise Tue, 26 May 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=72982