Deemed Manufacture – Mere activity of lebelling or re-lebelling is not amounting to manufacture

In Central Excise Tariff (Sections Notes and Chapter Notes), there are more that 50 entries to declare certain process as amounting to manufacture (even though these processes are not termed as manufacture in real terms)

For certain items, the process of labeling / re-lebelling activity is deemed manufactured if such activity is performed with the activity of packing / re-packing of goods.

In case a manufacture is not doing any activity regarding packing or repacking of goods, the mere process of lebelling or relebelling can not be held as deemed  manufacture for the purpose of excise duty. [See: COMMISSIONER OF C. EX., CHENNAI Versus INDIAN ADDITIVES LTD. - 2007 -TMI - 1394 - CESTAT, CHENNAI (excise section)]

Also see: -

Chapter Notes: - Central Excise

Section Notes: - Central Excise

List of processes amounting to manufacture - Central Excise (Chapter 5 of Central Excise Manual - an ebook)