COMMNR. OF CENTRAL EXCISE, CHANDIGARH vs M/S.MARKFED VANASPATI &ALLIED INDUSTRIES

The Supreme Court addressed whether 'spent earth' is liable for excise duty following the 1985 Tariff amendment which included it under a specific sub-heading. The central legal issue was whether a product becomes excisable solely by falling within a tariff item, or if the 'twin tests' of manufacture and marketability must still be satisfied. The Court examined whether the introduction of Tariff item 1507 overrode previous findings that 'spent earth' was not a manufactured product.