COMMNR. OF CENTRAL EXCISE, NEW DELHI vs M/S. S.R. TISSUES PVT. LTD.

The Supreme Court examined whether the process of cutting and slitting jumbo rolls of tissue paper constitutes 'manufacture' under Section 2(f) of the Central Excise Act, 1944. The Court held that such processes do not result in the emergence of a new product, thus not qualifying as manufacture. Consequently, the appeals filed by the department were dismissed, affirming the assessee's position that their activities did not attract excise duty under the relevant tariff headings.