TaxTMI 
TaxTMI 
1996 (12) TMI 77
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....liances Limited (PCA) buy goods which they call basic grill mechanism or griller from another firm named P.C.A. Electricals and bring them to their depot at a place called Nangal Shama. In that depot they pack the basic grill mechanism with other articles like sandwich plate, waffle plate, baking tray, tongs, spatula, surface scrubber, instruction-cum-recipe book and guarantee card. This assembly ....
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.... had also attached a control knob. This was a process of manufacturing. It was the view of the Collector that it was immaterial whether the process was a complicated or simple process but the fact is that the electrical goods were produced by undertaking this process. 2. When the matter came to the Tribunal, the Tribunal proceeded on the assumption that the PCA only packed the different equipment....
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.... of the case proceeding on the assumption that nothing was done by the PCA except to gather the various tax paid articles and put them in a box themselves and in the facts and circumstances of the case that would constitute manufacture. 3. The Tribunal's order is clearly erroneous. The Tribunal has not found whether a new product came into existence because of some activity undertaken by the appe....