Commissioner Of Central Excise, ... vs M/S. Markfed Vanaspati And Allied ...

The Supreme Court addressed whether 'spent earth' is liable for excise duty following its inclusion in a specific tariff item in the 1985 Tariff. The primary legal question was whether a commodity becomes excisable simply because it is listed within a tariff item, or if it must also satisfy the definition of 'manufacture' under the Central Excise Act. The Court examined the transition from previous holdings to the amended tariff to determine if the process of creating spent earth constituted a taxable manufacture.