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2018 (1) TMI 109 - BOMBAY HIGH COURTManufacture - activity of taking out footwear in finished form from the boxes bearing M.R.P. and labelling the same with their brand names “Metro” and “Mochi” and of putting them into the same boxes - Held that: - As admittedly, the footwear in finished form was received by the respondent, it is impossible to say that in the form in which the footwear was received, it could not be marketed or sold in open market by the respondent-assessee. Even without carrying out the activity of putting its brand name, the final product namely the footwear could have been marketed and sold to the consumers. Even assuming that one or two brand names affixed by the respondent are very popular, by affixing the brand name, at highest the value of the footwear will increase - on plain reading of subclause( iii) of clause (f) of Section 2, the activity does not amount to manufacture within the meaning of clause (f) of Section 2. On plain reading of subclause( iii) of clause (f) of Section 2, the activity does not amount to manufacture within the meaning of clause (f) of Section 2. Appeal dismissed.
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