https://www.taxtmi.com/caselaws?id=50569 Manufacture for excise purposes requires emergence of a new and distinct commercial commodity with a different name, character or use, and that test was not met where duty-paid chassis and cowl were body-fabricated by independent builders and only post-fabrication testing was done by the assessee. Ownership of the inputs or sale of the completed vehicles on invoices for the full value did not by itself make the assessee the manufacturer or attract duty on the full vehicle value. Section 11D was also inapplicable because liability under that provision fastens only on persons otherwise liable to duty, and there was no reliable proof of collection of excess excise duty; mere invoicing did not establish liability. en-us Thu, 12 Apr 2001 00:00:00 +0530 Mon, 23 Aug 2010 15:27:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=50569 Manufacture for excise purposes requires emergence of a new and distinct commercial commodity with a different name, character or use, and that test was not met where duty-paid chassis and cowl were body-fabricated by independent builders and only post-fabrication testing was done by the assessee. Ownership of the inputs or sale of the completed vehicles on invoices for the full value did not by itself make the assessee the manufacturer or attract duty on the full vehicle value. Section 11D was also inapplicable because liability under that provision fastens only on persons otherwise liable to duty, and there was no reliable proof of collection of excess excise duty; mere invoicing did not establish liability. Case-Laws Central Excise Thu, 12 Apr 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=50569