Manufacturer liability: excise duty attaches to the actual manufacturer and cannot be imposed jointly on multiple entities.
Central excise is an indirect tax triggered by manufacture of a new, marketable article; the liability for duty lies on the actual manufacturer who undertakes the manufacturing activity. Repair or reconditioning is not manufacture. Adjudication requires specific proof, and authorities have ruled that there cannot be two manufacturers of the same goods; joint and several demands against distinct legal entities without segregating individual liability are improper. (AI Summary)