Attaching Tags to Unpacked Parts Qualifies as "Deemed Manufacture" u/s 2(f)(iii) of Central Excise Laws.

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....Scope of the term Manufacture - deemed manufacture - the argument that putting a tag is not labelling or there is absence of container, etc., in our view, will defeat the purpose of definition given in Section 2(f)(iii). In view of the said position, we hold that even putting the tag on the unpacked parts will amount to manufacture and will be covered under Section 2(f)(iii) - AT....