The upgrading of old and used computer systems would not amount to manufacture, in so far as the upgradation does not bring into existence goods with a distinct new name, character and use

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....on the activity of upgradation of computer system and addition of hard disk - regarding I am directed to say that certain doubts have been expressed whether upgradation of computer system by increasing the storage/processing capacity of computer system etc. will amount to manufacture under the Central Excise Act, 1944. 2. The matter has been examined by the Board. It is observed that compute....

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.... the components in existing system have already suffered duty. The remaining old parts of the old system have also suffered duty as a system initially. The upgradation is generally carried out at residential or business premises of the customer and there is no rigid requirement for the upgradation to be done at the factory of the manufacturer. The value addition in such upgradation involved, wheth....