“Supreme Court Expands Definition of ‘Manufacture’: Labeling Alone Qualifies for Cenvat Credit and Rebate” Central Excise Act, 1944 – Section 35L(1)(b) – qualification as ‘manufacture’ under the Act – The primary issue is whether the labeling activity constitutes ‘manufacture’ as per Note 3 to Chapter 18 of the Central Excise Tariff Act, thereby making respondent eligible for cenvat credit and rebate on exported goods – The revenue (petitioner) argued that the additional labeling done by Respondent did not amount to manufacture and hence, they were not entitled to the cenvat credit and rebate claims – Respondent contended that the labeling activity is deemed as manufacture according to Note 3 to Chapter 18 of the Central Excise Tariff Act, justifying their claims for cenvat credit and rebate – The Supreme Court affirmed the CESTAT’s order, dismissing the revenue’s appeal and upholding Jindal Drugs Ltd.’s entitlement to cenvat credit and rebate on the duty paid – The Court reasoned that the amendment to Note 3, which replaced ‘and’ with ‘or’, broadened the scope of activities considered as manufacture, including labeling – The Court interpreted the definition of ‘manufacture’ in the Central Excise Act and the amended Note 3 to Chapter 18, concluding that labeling alone suffices as manufacture – The Supreme Court concluded that the labeling activity carried out by respondent amounts to manufacture, entitling them to cenvat credit and rebate, with no order as to costs.