2002 (1) TMI 171

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.... purchased mould release preparation classifiable under Heading 3403 from its importer, Castrol Ltd. It packed this into small aerosol 500 ml cans, putting in these cans the gas required to propel the substance. In the order impugned in this appeal, the Commissioner (Appeals) has confirmed the finding of the Asstt. Collector impugned before him that this activity amounted to manufacture. 2.&#8195....

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.... of manufacture, in the absence of a deeming provision in law to this effect. At the relevant time, there was no provision that repacking of these goods amounted to manufacture. It is also not correct to say that the mode of use has changed. The use of the preparation was by applying it to the surface work piece. It is the method of such application that has changed. This change alone does not sat....