PROCTOR & GAMBLE HYGIENE&HEALTH CARE LTD vs COMMNR. OF CENTRAL EXCISE, BHOPAL

The Supreme Court ruled on the applicability of excise duty under the Central Excise Act, 1944, specifically addressing whether the cost of repacking detergent powder into smaller sachets constituted a manufacturing activity. The Court held that prior to the introduction of Chapter Note 6 on 1.3.1994, such repacking did not amount to manufacture, and thus, the cost was not includible in the assessable value for duty purposes. The appeal was allowed, overturning the tribunal's decision that had imposed a differential duty on the appellants.