https://www.taxtmi.com/caselaws?id=91258 Repair and reconditioning of returned rollers by dismantling, cleaning, replacing parts, reassembling and painting did not amount to manufacture because the goods emerged in substantially the same form and were not shown to be commercially different from the goods received. The article also notes that the department could not sustain the demand on grounds not included in the show cause notice, including absence of duty-paying documents and prior permission, because such new grounds could not be introduced at the appellate stage under Section 35E of the Central Excise Act, 1944. The impugned orders were set aside and the appeals were allowed. en-us Tue, 18 Aug 1998 00:00:00 +0530 Fri, 14 Oct 2011 18:23:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=91258 Repair and reconditioning of returned rollers by dismantling, cleaning, replacing parts, reassembling and painting did not amount to manufacture because the goods emerged in substantially the same form and were not shown to be commercially different from the goods received. The article also notes that the department could not sustain the demand on grounds not included in the show cause notice, including absence of duty-paying documents and prior permission, because such new grounds could not be introduced at the appellate stage under Section 35E of the Central Excise Act, 1944. The impugned orders were set aside and the appeals were allowed. Case-Laws Central Excise Tue, 18 Aug 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=91258