https://www.taxtmi.com/caselaws?id=51786 Affixing an assessee's own label and particulars on helium gas cylinders received already filled by another manufacturer did not amount to manufacture under Note 10 of Chapter 28. The deeming provision for manufacture, covering labelling, re-labelling, repacking from bulk to retail packs, or other treatment to make goods marketable, must be applied strictly. On the facts, the activity was limited to receiving filled cylinders, testing the gas and adding the assessee's name and particulars; it was not shown to involve repacking or any statutory treatment rendering the product marketable. The duty demand and penalties were therefore not sustainable. en-us Thu, 04 Apr 2002 00:00:00 +0530 Tue, 28 Sep 2010 12:29:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=51786 Affixing an assessee's own label and particulars on helium gas cylinders received already filled by another manufacturer did not amount to manufacture under Note 10 of Chapter 28. The deeming provision for manufacture, covering labelling, re-labelling, repacking from bulk to retail packs, or other treatment to make goods marketable, must be applied strictly. On the facts, the activity was limited to receiving filled cylinders, testing the gas and adding the assessee's name and particulars; it was not shown to involve repacking or any statutory treatment rendering the product marketable. The duty demand and penalties were therefore not sustainable. Case-Laws Central Excise Thu, 04 Apr 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=51786