(1.) Heard both sides.
(2.) Revenue filed this appeal against the order -in -appeal passed by the Commissioner (Appeals) whereby the Commissioner (Appeals) held that mere putting colour cakes in a box along with brush does not amount to manufacture.
(3.) Brief facts of the case are that the respondents are engaged in the manufacture of water colour boxes. Respondents were purchasing colour cakes from M/s. Ashok Enterprises and were putting these colour cakes in the box along with brush.