Business Law

Excise Duty Exemption: No Benefit if Any Manufacturing Step Uses Power NEW

Supreme Court rules that excise duty exemption for goods "processed without aid of power" is not available if any integral process in the manufacturing chain uses power, even if performed by separate units.

Case Reference: Commissioner of Customs, Central Excise & Service Tax, Rajkot vs Narsibhai Karamsibhai Gajera & Ors. (Civil Appeal Nos.3405-3407 of 2012) Decided by: Supreme Court of India Date: December 2, 2025

❓ Questions

(i) WHETHER UNITS CLAIMING EXEMPTION UNDER NOTIFICATION NO.5/1998-CE (ENTRY NO.106) FOR "COTTON FABRICS PROCESSED WITHOUT THE AID OF POWER" CAN CLAIM BENEFIT IF ANY INTEGRAL PROCESS IN THE MANUFACTURING CHAIN USES POWER?

(ii) WHETHER THE ENTIRE MANUFACTURING PROCESS FROM RAW MATERIAL TO FINISHED PRODUCT MUST BE CONSIDERED AS A WHOLE FOR DETERMINING ELIGIBILITY FOR EXCISE DUTY EXEMPTION?

(iii) WHETHER SEPARATE MANUFACTURING UNITS OPERATING IN A CONTINUOUS PROCESS CAN BE TREATED AS A SINGLE MANUFACTURING CHAIN FOR EXCISE DUTY PURPOSES?

(iv) WHETHER THE CESTAT ERRED IN BIFURCATING THE CONTINUOUS MANUFACTURING PROCESS AND GRANTING EXEMPTION BASED ON SEPARATE UNIT OPERATIONS?

✅ Answers

(i) NO - The exemption under Notification No.5/1998-CE (Entry No.106) is not available if any integral process in the manufacturing chain uses power, regardless of whether different units perform different processes.

(ii) YES - The entire manufacturing process from raw material to finished product must be considered as a whole for determining eligibility for excise duty exemption. The cumulative effect of all processes must be examined.

(iii) YES - When separate manufacturing units operate in a continuous, integrated process leading to a final product, they must be treated as a single manufacturing chain for excise duty purposes.

(iv) YES - The CESTAT committed an error by bifurcating the continuous process of manufacture and treating separate units as independent operations when they were integrally connected in the manufacturing chain.

⚖️ Understanding the Legal Principles

🔹 Manufacturing Process Must Be Viewed Holistically

  • All processes from raw material to final product considered together
  • Cannot isolate individual processes to claim exemption
  • Even ancillary processes using power disqualify exemption
  • Cumulative effect of all processes determines eligibility

🔹 Separate Units in Same Premises Treated as One

  • Units operating in same premises with continuous process
  • Transfer of intermediate goods between units
  • Final product emerges only after all processes complete
  • Separate ownership doesn't matter for excise purposes

🔹 Power Usage in Any Process Disqualifies Exemption

  • Exemption requires "processed without aid of power"
  • If ANY process uses power, exemption not available
  • Even if main process doesn't use power but ancillary does
  • Power usage outside factory also disqualifies exemption

🔹 Definition of "Manufacture" is Broad

  • Includes any process incidental to completion
  • Series of processes leading to final product
  • Each step towards production is a "process"
  • Continuous and regular actions constitute manufacturing

📜 Key Legal Timeline

Jan 21, 2003

Search & Panchnama: Preventive staff searches Bhagyalaxmi Processor Industry (Unit 1) and Famous Textile Packers (Unit 2), finds machinery using power

Jul 14, 2003

Show Cause Notice: Commissioner issues notice alleging units not entitled to exemption due to power usage

Jul 29, 2004

Order-in-Original: Commissioner holds units liable to pay duty with interest and penalty

Jul 1, 2005

First CESTAT Order: Sets aside order and remands case for reconsideration of joint liability

Sep 27, 2006

Re-adjudication Order: Commissioner confirms demand against Unit 1 only, imposes penalty

Oct 5, 2011

CESTAT Final Order: Allows appeals, sets aside Commissioner's order, grants exemption to units

Dec 2, 2025

Supreme Court Ruling: "No excise duty exemption if any manufacturing step uses power" - sets aside CESTAT order, restores Commissioner's order

🧭 Your Action Plan: Excise Duty Exemption Compliance

📝 If Claiming "Processed Without Power" Exemption

✅ Verify Entire Manufacturing Chain

  • Check ALL processes from raw material to finished goods
  • Include ancillary and incidental processes
  • Verify even processes done by third parties/contractors
  • Document power usage/non-usage for each step

✅ Maintain Proper Records

  • Keep detailed process flow documentation
  • Record power consumption for each machine/process
  • Maintain contractor agreements showing power usage
  • Document alternative power sources if any

✅ Beware of Integrated Units

  • Treat all integrated units as single manufacturing chain
  • Don't separate units for exemption claims
  • Consider physical proximity and process continuity
  • Transfer of intermediate goods indicates integration

⚖️ Key Legal Provisions to Reference

Legal Provision What It Means Application in This Case
Notification 5/1998-CE Entry 106
Exemption for cotton fabrics
Exempts cotton fabrics processed without aid of power or steam Not applicable if ANY process in chain uses power
Section 2(f) Central Excise Act
Definition of "Manufacture"
Includes any process incidental or ancillary to completion Broad interpretation covers all processes in chain
Section 35-L(b) Central Excise Act
Appeal to Supreme Court
Allows appeal against CESTAT order on substantial question of law Invoked due to misinterpretation of exemption notification
Standard Fireworks Case
(1987) 1 SCC 600
Exemption not available if any process uses power Applied - power usage in ANY process disqualifies exemption

📘 Key Legal Terms Explained

Manufacture (Section 2(f))

Includes any process incidental or ancillary to completion of manufactured product, any specified process in tariff notes, and packing/treatment to render product marketable.

Process

A continuous and regular action or succession of actions taking place in definite manner leading to accomplishment of result. Can include handling, use, or transformation of materials.

Panchnama

Document recording search and seizure proceedings, prepared in presence of independent witnesses (panchas), used as evidence in excise and customs proceedings.

CESTAT

Customs, Excise and Service Tax Appellate Tribunal - specialized tribunal for appeals against orders of Commissioner of Customs and Central Excise.

🚨 What to Avoid in Excise Exemption Claims

❌ Don't Isolate Processes for Exemption

  • Don't claim exemption based on isolated processes
  • Avoid separating integrated manufacturing steps
  • Don't ignore ancillary/incidental processes
  • Avoid claiming exemption for part of process only

❌ Don't Ignore Power Usage in Any Step

  • Don't overlook power usage in minor processes
  • Avoid claiming exemption if ANY process uses power
  • Don't separate units operating in continuous process
  • Avoid incomplete power usage documentation

💡 Core Takeaway from the Supreme Court

"Manufacture involves a series of distinct processes. It is the cumulative effect of the various processes to which the raw material is subjected after which the manufactured product emerges. The requirement is that the individual process should be integrally connected with each other leading to the ultimate final product. But for each individual process, the manufacture or processing of the goods would be impossible."

This judgment establishes that excise duty exemptions requiring "processing without aid of power" must be interpreted strictly. If ANY integral process in the manufacturing chain uses power, the exemption is not available, regardless of whether different units perform different processes or whether the units have separate ownership.

📞 When to Seek Professional Help

👨‍⚖️ Legal Counsel Essential For

  • Structuring manufacturing processes for exemption
  • Responding to show cause notices from excise department
  • Appeals before CESTAT and higher courts
  • Complex exemption notification interpretations
  • Multi-unit manufacturing arrangements

📝 You Can Handle With Support

  • Basic understanding of exemption notifications
  • Initial assessment of manufacturing process compliance
  • Basic record keeping for exemption claims
  • Understanding when power usage disqualifies exemption
  • Monitoring manufacturing process changes

⚠️ DISCLAIMER

This content is for informational purposes only and does not constitute legal advice. Consult a qualified legal professional for specific legal guidance. The information provided is based on judicial interpretation and may be subject to changes in law.

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This analysis decodes a complex excise duty judgment to help businesses understand exemption requirements and compliance obligations.