Commissioner Of Central Excise, Mumbai vs Boc (I) Ltd.

The Supreme Court upheld the Tribunal's decision that the respondent's activity of labeling or re-labeling does not constitute 'manufacture' under Note 10 of Chapter 28 of the Central Excise Tariff. The Court referenced the precedent set in Commissioner of Central Excise, Mumbai v. Johnson & Johnson Ltd., which clarified that mere labeling without repacking from bulk to retail packs does not render a product marketable. Consequently, the appeals were dismissed, affirming that no excise duty was applicable in this case.