TMI Blog1999 (7) TMI 488X X X X Extracts X X X X X X X X Extracts X X X X ..... Member (T)]. The appellant, Pearl Soap Co., manufactures, out of raw material supplied by Wipro Ltd., soap which it returns to the latter. It cleared for the purposes of payment of duty, the value of the soap has been total of the cost of raw material, its manufacturing charges and profit earned by it. In the order impugned in the appeal, the Commissioner (Appeals) has confirmed the finding ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... having a distinct name and character, it is the person or persons who engage upon such transformation who would be the manufacturer. This, in this case, was done by the appellant. The appellant is the manufacturer. The Commissioner accepts that the value to be determined under Section 4(1)(b) of the Act, i.e. by application of Valuation of Rules. The appropriate rule to be applied is 6(b)(2). [Th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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