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    <description>Mere aggregation of duty-paid tyres, tubes and flaps with strapping, inspection and hologram affixation did not amount to manufacture under section 2(f) of the Central Excise Act, 1944, because the record did not show that the goods were previously unmarketable or that the process universally made them marketable. Hologram affixation was treated as branding-related treatment, not a manufacturing process. The duty demand also failed for want of a proper statutory basis in classification and valuation, since the order departed from the existing assessment framework without support. The consequential demand was therefore unsustainable and the appeals succeeded.</description>
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