Assessee entitled to refund of Special Additional Duty as labeling and repacking of gloves don't qualify as manufacturing.

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....Refund of SAD - the imported gloves have been sold by the assessee as gloves and it is only by deeming fiction of law that the activities of labeling, relabeling, packing, repacking etc., has been made as amounting to manufacture, we find that there is no justification to hold that the gloves have undergone any change.....