M/S. POONAM SPARK (P) LTD. vs COMMNR. OF CENTRAL EXCISE, NEW DELHI

The Supreme Court examined whether the assembly of Water Purification and Filtration Systems (WPFS) by M/s Poonam Spark (P) Ltd. constituted 'manufacture' under Section 2(f) of the Central Excise Act, 1944. The Court held that the assembly did not result in a new product, as the WPFS retained its identity and character, thus the appellant was not liable for excise duty. The decision of the Adjudicating Authority was set aside, ruling in favor of the appellant.