Commissioner Of Central Excise Belapur vs Jindal Drugs Ltd

The Supreme Court addressed the appeal under Section 35L(1)(b) of the Central Excise Act, 1944, challenging the CESTAT's ruling that labelling constituted manufacture under Note 3 to Chapter 18 of the Central Excise Tariff Act, 1985. The Court upheld the CESTAT's decision, affirming that the respondent was entitled to cenvat credit and rebate on duties paid, as the activity of labelling did not amount to manufacture that would enhance marketability. The Court also ruled that there was no suppression of facts by the respondent, negating the extended limitation period for the revenue's claims.