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TMI Blog2013 (12) TMI 910X X X X Extracts X X X X X X X X Extracts X X X X ..... within the meaning of clause (f) of Section 2 of the Central Excise Act, 1944. Said Section 2(f)(iii) defines ‘manufacture’ as a process which involves packing or repacking of such goods in a unit container or labelling or re-labelling of containers or adoption of any other treatment on the goods to render the product marketable to the consumer - inasmuch as the paper becomes marketable only after ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e appearing for the appellant and Shri Nagesh Pathak, ld. A.R. appearing for Revenue we find that said amount of Service tax stands confirmed against the appellant on the ground that they have undertaken the activity of packaging of paper produced by M/s. J.K. Paper Ltd. The appellant has installed its packing machine and strapping machine in the factory of M/s. J.K. Paper Ltd. who are engaged in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... it stands pleaded before us that inasmuch as the paper becomes marketable only after the same is duly packed in the wrapping paper, the said activity has to be held as manufacturing activity. 4. We find that in terms of said definition of manufacture the activity undertaken by the appellant is manufacturing activity. If that be so, the same cannot be held to be packaging activity in terms of t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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