The appellant (M/s. Sepack) engaged in trading sealing machines manufactured by various independent...

The appellant (M/s. Sepack) engaged in trading sealing machines manufactured by various independent Decentralized Mother Units (DMUs) during the relevant period. DMUs claimed SSI exemption under Notification No. 08/2003-CE, with clearances below Rs. 150 lakhs. Revenue alleged DMUs were dummy units created and controlled by Sepack to claim SSI exemption benefit. Revenue contended sealing machines attained marketable character after quality checking, branding, labeling, and warranty processes by Sepack, making Sepack the manufacturer. The Tribunal observed DMUs existed physically, with commercial negotiations between Sepack and DMUs for cost optimization. DMUs supplied complete sealing machines to Sepack, which only inspected, branded, packed..... .....

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