The case of the Revenue is that the PCA had manufactured what they call twink informatics cuisinette.
PCA also buys what they call electric stove from M s. P.C.A. Electricals and pack it together in one box with one companyk n serve bowl, a companyster cum meat rack, glass lid, instructions cum recipe book, and sell these assembled goods as twink simmermatic cuisinette.
At the stage of the Collector, the Revenues case was that there was some manufacturing process undertaken by PCA.
It was the view of the Collector that it was immaterial whether the process was a companyplicated or simple process but the fact is that the electrical goods were produced by undertaking this process.
This was a process of manufacturing.
The case of the PCA is that these are duty paid goods which they bought and they merely packed these goods and sold them.
This assembly is sold by M s. P.C.A. as a unit of twink informatics cuisinette.
C. Sen, J. The facts of the case as stated by the Tribunal are that M s. Pressure Cookers and Appliances Limited PCA buy goods which they call basic grill mechanism or griller from another firm named P.C.A. Electricals and bring them to their depot at a place called Nangal Shama.
In that depot they pack the basic grill mechanism with other articles like sandwich plate, waffle plate, baking tray, tongs, spatula, surface scrubber, instruction cum recipe book and guarantee card.
According to the Collector PCA put the companyponents together and had affixed a heat companytrol panel plate with its name on the product and had also attached a companytrol knob.
When the matter came to the Tribunal, the Tribunal proceeded on the assumption that the PCA only packed the different equipments pieces and items that they bought from different people at their depot at Nangal Shama and that they do number manufacture the companyponents.
