https://www.taxtmi.com/caselaws?id=791302 Repacking bulk epoxy resin, hardeners and colours into smaller containers, without any change in identity, character or use, was treated as a mere packaging activity and not manufacture under the Central Excise Act, 1944. The deeming fiction for packing or repacking applied only where the goods were covered by the relevant statutory schedule or chapter note, which was not the case here. Classification provisions for tariff entry could not, by themselves, convert the activity into manufacture. The demand based on a manufacture theory was therefore unsustainable. en-us Tue, 28 Apr 2026 00:00:00 +0530 Sat, 09 May 2026 07:13:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791302 Repacking bulk epoxy resin, hardeners and colours into smaller containers, without any change in identity, character or use, was treated as a mere packaging activity and not manufacture under the Central Excise Act, 1944. The deeming fiction for packing or repacking applied only where the goods were covered by the relevant statutory schedule or chapter note, which was not the case here. Classification provisions for tariff entry could not, by themselves, convert the activity into manufacture. The demand based on a manufacture theory was therefore unsustainable. Case-Laws Central Excise Tue, 28 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791302