In Brief
A company manufactures cocoa butter at its Jammu unit and labels it at a separate Taloja unit before export, claiming Cenvat credit on duty paid. The revenue denied the credit, arguing relabelling did not constitute manufacture. The Supreme Court held that under Note 3 to Chapter 18 of the Central Excise Tariff Act (as amended in 2008), relabelling of containers is an independent process amounting to manufacture. The court affirmed that the company was entitled to avail Cenvat credit and export rebate, as the statutory interpretation issue involved no factual suppression, thus no extended period applied.
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