[Civil Appeal No. 2684 of 2012]. The question of law which arises for consideration in the present case is whether the activity of mounting of Water Purification and Filteration System (WPFS) on a base frame carried out by M/s Poonam Spark (P) Ltd. amounts to manufacture or not. The aforesaid issue is to be determined in the following factual background: One M/s Perfect Drug Limited (PDL) had been purchasing/importing various components of WPFS classifiable under Tariff Heading 8421. PDL, after importing these materials, supplied the same to the appellant herein. Job work was assigned to the appellant for the assembly of WPFS on behalf of PDL. Appellant takes job charges from PDL. Various parts which were supplied by the PDL to the appellant were as follows: Filter Housing & Cartridge UV Units Timer Mounting Plate & screws Tubings and Fittings According to the Department of Revenue, the aforesaid work being carried out by the appellant, namely, assemble of the components resulted into a new product known as WPFS having different name and character and it amounted to "manufacture" as per Section 2(f) of the Central Excise Act, 1944 and, therefore, appellant was liable to pay excise duty.
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