M/S. Satnam Overseas Ltd vs Commnr. Of Central Excise, New Delhi

The Supreme Court examined the classification of a product under the Central Excise Tariff Act, 1985, specifically addressing whether the process of mixing raw rice, dehydrated vegetables, and spices constituted 'manufacture' as defined under Section 2(f) of the Central Excise Act, 1944. The Court held that the process did not result in a new product, affirming that the mixture remained fundamentally rice and thus did not qualify as manufacture. Consequently, the Court ruled in favor of the appellant, determining that the product should be classified under Heading 11.01, which incurs no duty.