https://www.taxtmi.com/caselaws?id=1394 Labelling imported lubricating oil additive barrels with the importer's name, address and brand name, together with sampling, testing and enclosing test certificates, was held not to amount to manufacture under Note 5 to Chapter 38. The labelling was done to satisfy mandatory packaging requirements, not to make the goods marketable, and the goods were sold in the same barrels without repacking from bulk to retail packs. Sampling and testing were treated as quality assurance for customer specifications rather than a marketability-enhancing process. A later departmental circular was held inapplicable to the disputed period because it had no retrospective effect, so the duty demand and related proposals were not sustainable. en-us Wed, 21 Mar 2007 00:00:00 +0530 Mon, 14 Apr 2008 17:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=1394 Labelling imported lubricating oil additive barrels with the importer's name, address and brand name, together with sampling, testing and enclosing test certificates, was held not to amount to manufacture under Note 5 to Chapter 38. The labelling was done to satisfy mandatory packaging requirements, not to make the goods marketable, and the goods were sold in the same barrels without repacking from bulk to retail packs. Sampling and testing were treated as quality assurance for customer specifications rather than a marketability-enhancing process. A later departmental circular was held inapplicable to the disputed period because it had no retrospective effect, so the duty demand and related proposals were not sustainable. Case-Laws Central Excise Wed, 21 Mar 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=1394