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As per case facts, M/s Basant Industries arranged for other licensed units to manufacture power-driven pumps under its brand. The Central Excise Department disputed an exemption claim under Notification No.
...85/72, alleging the pumps were made on the appellant's behalf. The appellant countered that it supplied raw materials to independent units operating without its control. The Tribunal, while acknowledging no control by the appellant over the manufacturing process, denied the exemption, reasoning that supplying components implied manufacturing on its behalf, especially considering the low charges paid to units. The question arose whether pumps manufactured by independent units, using components supplied by the appellant, constituted manufacturing "on behalf of" the appellant, thereby denying its exemption claim. Finally, the Supreme Court allowed the appeal, holding that the oil-driven pumps were not manufactured by the appellant, thus entitling it to the exemption. The Court clarified that the Tribunal, having found no control by the appellant, misdirected itself by concluding "manufacturing on behalf of" solely based on component supply. It stressed that independent units processed the components for payment, and extending the notification's scope beyond actual manufacturing by or under the control of the appellant was unwarranted.
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