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2018 (6) TMI 1142 - AT - Central ExciseManufacture - conversion of tissue papers, C-fold tissue, M-fold tissue, paper napkin/serviette of different sizes, toilet roll, kitchen roll, JRT roll and HRT roll etc. from jumbo rolls of paper - whether the activity carried out by the appellant in their factory amounts to manufacture? - Held that:- There is no doubt that the final products of the appellant are perceived in the market place as different from the jumbo rolls which are raw materials. No doubt both the jumbo rolls and final products such as napkins are made of the same tissue paper. But there is no doubt that the transformation of jumbo rolls into either toilet rolls/ kitchen rolls or in the form paper napkins bring out a distinctive and different use in the article. Evidently, the resultant products are perceived differently in the market - The process undertaken by the appellant is to be considered as a process of manufacture. The liability for payment of excise duty is, therefore, incurred by the appellant. Time Limitation - Held that:- The demand upheld even on the basis of extended time limit. Appeal dismissed - decided against appellant.
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