VidhiSangh

Supreme Court of India · 19/09/2025

M/S QUIPPO ENERGY LTD. versus COMMISSIONER OF CENTRAL EXCISE AHMEDABAD – II

[2025] 9 S.C.R. 1110 · 2025 INSC 1130

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Summary

The Supreme Court held that placing imported gas generating sets in steel containers and fitting the containers with radiators, ventilation fans, air filters, oil tanks, pumps, valves, silencers and piping to produce leased 'Power Packs' amounts to manufacture under Section 2(f)(i) of the Central Excise Act, 1944. The added components are parts, not accessories; the re-engineered portable product has a distinct character and identity and is marketable, so excise duty was payable.

Issues

  1. Whether placing an imported Genset within a steel container and fitting the container with components such as radiator, ventilation fan, air filter unit, oil tank, pipes, pumps, valve and silencer amounts to manufacture under Section 2(f) of the Central Excise Act, 1944.
  2. How the two-fold test of transformation and marketability for manufacture is to be applied, including the 'but for the process' limb.
  3. Whether the components added were parts or accessories of the resulting Power Pack.

Provisions considered

Held

Result

Appeals dismissed; the CESTAT's finding that the activity amounts to manufacture and the duty demand for the normal period were left undisturbed.

Judgment PDF: Supreme Court of India, [2025] 9 S.C.R. 1110.