Summarize the following court judgment. ivil Appeal No. 1589 of 1988 etc. From the Order dated 6.1.1988 of the Customs Excise and Gold (Control) Appellate Tribunal	 New Delhi in Appeal No. 2085 of 1985A in Order No. 5 of 1988 A. K. Parasaran	 Attorney General	 A.K. Ganguli	 K. Swamy	 P. Parmeswaran and Sushma Suri for the Appellant. R.N. Bajoria	 S.K. Bagaria	 Padam Khaita	 Vivek Gambhir	 Praveen Kumar	 S.K. Bagga and R.K. Mehta for the Respond ents. The Judgment of the Court was delivered by SABYASACHI MUKHARJI	 J. These appeals are at the in stance of the revenue under section 35 L of the Central Excises & Salt Act	 1944 (hereinafter referred as to 'the Act '). Civil Appeal No. 1589 appeal arises out of Order No. 5 of 1988 A passed by the Customs	 Excise and Gold (Control) Appellate Tribunal	 New Delhi (hereinafter referred to as 'the Tribunal '). The. respondent used to manufacture different varieties of printing paper including wrapping paper falling under Item No. 17(1) of the erstwhile Central Excise Tariff in their factory at Bansberia	 District Hubli. It is the appel lant 's case that the respondent had violated the 1020 provisions of Rule 9(1)	 Rule 173 F and Rule 173 G of the Central Excise Rules	 1944 inasmuch as they had removed 4	000 kgs. of wrapping paper under Gate Pass No. A 460 dated 9th February	 1984 and 485 dated 17th February	 1984 valued at Rs. 13	200 without payment of central excise duty. Show cause notice was issued to the respondent as to why appro priate duty of excise amounting to Rs.3	600 (basic)	 Rs. 180 (special) and Rs. 16.50 (cess) totalling Rs.3	796.50 should not be recovered from them on the said quantity at the rate of Rs.900 per M.T. and special duty at the rate of 5% of basic duty and cess 1/8% on value. Notice to show cause as to why penalty should not be imposed was also issued. Cause was shown by the respondent. It was the contention of the respondent that there was no infringement of the impugned provision and no duty was required to be paid on the excisa ble goods if it was captively consumed or utilised in the same factory as component part of the finished goods falling under the same tariff item and specified in Rule 56(a) of the Central Excise Rules	 1944. It was further stated that in the instant case	 wrapped paper manufactured was captive ly consumed and utilised as component part of other varie ties of paper. Wrapping	 it was contended	 of finished product by wrapping paper is a process incidental and ancil lary to the completion of manufactured product under section 2(f) of the Act and wrapping is used as a component part of finished excisable goods attracting the benefit of the notification No. 18A 83 CE dated 9th July	 1983. The Super intendent (Technical) of Central Excise held otherwise. The respondent preferred an appeal before the Collector (Ap peals)	 Calcutta. The respondent contended before the Col lector that they were entitled to the benefit of notifica tion and it is well settled law in view of several judgments of High Court and orders of the Tribunal that wrapping of paper was a process incidental or ancillary to the comple tion of manufacture of paper	 as the printing and writing paper could not be sold in the market without being packed and wrapped by wrapping paper. The Collector (Appeals)	 however	 rejected the claim to exemption in respect of such wrapping paper in terms of the proviso to Rule 9(1). There was an appeal to the Tribunal. The Tribunal referred to its own decision in the case of Collector of Central Excise	 Bhubneshwar vs Orient Paper Mills	 Brajraj Nagar	 135	 which is the subject matter of the other appeal involved herein	 and set aside the order of Collector. Similar is the case in Civil Appeal Nos. 3760 62 of 1988. In that case	 M/s. Orient Paper Mills	 Brajraj Nagar	 respondents	 were manufacturers of various types of paper and paper board. They were also the manufacturers of wrap ping paper for packing or wrapping of 1021 other varieties of paper. Under the relevant notification	 the Central Government had exempted duty in respect of goods if these were consumed or utilised in a place where such goods were produced or manufactured under relevant rule either as raw materials or component parts for the manufac ture. Therefore	 in order to get the benefit of non levy of excise duty on wrapping paper	 it had to be established in both these appeals that the wrapping papers were consumed or utilised by the respondent assessees as component parts or raw materials for the finished products. The Collector (Appeals) in his order observed that when wrapping paper was used for making paper reams/reals	 it lost its original identity as wrapping paper and became a part and parcel of the paper ream/real and as such available for the benefit of amended Rules. Revenue disputed this finding. It was contended that the wrapping paper was not utilised or consumed in the manufacture of other paper. On behalf of the revenue	 it was contended before us in these appeals that in order to be non dutiable	 the wrapping paper must be either component part or raw material and must be consumed or utilised in the manufacture of the finished products. Wrapping paper cannot	 it was contended	 be deemed to be component part because it did not become an integral part of the packed paper. In this connection	 on behalf of the revenue	 learned Attorney General drew our attention to the fact that reliance had been placed on the decision of the Kerala High Court in Paul Lazar vs State of Kerala	 [1977] 40 STC 437. On behalf of the respondent	 however	 Shri Bajoria placed reliance on section 2(f) of the Act which includes any process incidental or ancillary to the completion of a manufactured product. Therefore	 it was urged that all processes leading upto the stage of goods	 when the goods become completed for marketing would be within the process of marketing. In that view of the situa tion	 it was urged that wrapping paper was raw material or component part of the wrapped paper. It was further urged that revenue had itself considered the stage of wrapped or packed paper as the R.G.I. stage	 i.e.	 the stage at which goods should be entered in the statutory production regis ter. 'Manufacture ' in the sense it is used in the excise law	 was not complete until and unless wrapping was done. It is law now that excise is a duty on manufacture. Manufacture is the process or activity which brings into existence new	 identifiable and distinct goods. Goods have been understood to be articles known as identifiable articles known in the market as goods and marketed or marketable in the market as such. See in this connection the observations of this Court in Bhor Industries Ltd.	 Bombay vs Collector of Central Excise Bombay	 602; South Bihar Sugar Mills Ltd.	 etc. vs Union of India & Ors. 	 ; ; Union of India vs Delhi Cloth & General Mills Ltd.	 [1963] Supp. 1 SCR 586 and Union Carbide India Ltd. vs Union of India and Ors.	 See also the decision of this Court in Civil Appeal No. 2215(NA) of 1988 Collector of Central Excise	 Baroda vs M/s Ambalal Sarabhai Enterprises	 judgment delivered on 10th August	 1989. The finished goods were cut to size and packed paper which	 according to the Indian Standard and trade practice	 consisted of the wrapping paper and the wrapped paper. In South Bihar Sugar Mills Ltd. 's	 case (supra)	 it was held by this Court that the duty is levied on goods. As the Act does not define goods	 the legislature must be taken to have used that word in its ordinary	 dictionary meaning. The dictionary meaning of the expression is that to become 'goods ' it must be something which can ordinarily come to the market to be bought and sold and is known to the market as such. The Tribunal found	 and there was material for the Tribunal to do so	 that the market in which articles in question were sold were paper packed and wrapped in paper. Therefore	 anything that enters into and forms part of that process must be deemed to be raw material or component part of the end product and must be deemed to have been used in completion or manufacture of the end product. This Court in the case of Empire Industries Ltd. & Ors. vs Union of India & Ors. 	 ; has explained the concept of 'process ' in Excise Law. In view of the principle laid down therein and other relevant decisions	 processes incidental or ancillary to wrapping are to be included in the process of manufacture	 manufacture in the sense of bringing the goods into existence as these are known in the market is not complete until these are wrapped in wrapping paper. In J.K. Cotton Spinning and Weaving Mills Co. Ltd. vs Sales Tax Officer	 [1965] 16 STC 563 (SC)	 this Court while construing the expression 'in the manufacture or processing of goods for sale ' in the context of Sales Tax Law	 though the concept is different under the Excise Law	 has held that manufacture of goods should normally encompass the entire process carried on by the dealer of converting raw materials into finished goods. Where any particular process	 this Court further emphasised	 is so integrally connected with the ultimate production of goods that	 but for that process	 manufacture or processing of goods would be commercially inexpedient	 articles required in that process	 would fall within the expression 'in the manufacture of goods '. The Tribunal on the appraisement of all the relevant facts in the light of the principles indicated before	 upheld its own decision in the case of Orient Paper Mills. and in both the appeals accepted 1023 the manufacturer 's contentions and dismissed the appeal. The revenue contends that the Tribunal has erred. Shri Bajoria for the respondent	 drew our attention to the decision of this Court in Collector of Central Excise vs Jay Engineering Works Ltd.	 There the respondent was the manufacturer of electric fans	 and brought into its factory nameplates under Tariff Item 68 of the erstwhile Central Excise Tariff. The nameplates were affixed to the fans before marketing them. The respondent claimed the benefit of proforma credit in terms of notifica tion No. 201/79 dated 4th June	 1979	 which was for the purpose of relief on the duty of excise paid on goods fall ing under Tariff Item 68	 when these goods were used in the manufacture of other excisable goods. The said notification stated that in supersession of the Notification No. 178/77 of the Central Excise dated 18th June	 1977	 all excisable goods on which duty of excise was leviable and in the manu facture of which any goods falling under Item No. 68 have been used	 were exempt from so much of the duty of excise leviable thereon as was equivalent to the duty of excise already paid on the inputs. In that case	 the question before the Tribunal was whether the nameplates could be considered as component part of the electric fan	 so as to be eligible for proforma credit under the exemption notifi cation. It was found by the Tribunal that no electric fan could be removed from the factory for being marketed without the nameplate. The Tribunal also noted in that case that even though it could be said that electric fans could func tion without the nameplates	 for actual marketing of the fans	 the affixation of the nameplate was considered an essential requirement. To be able to be marketed or to be marketable	 it ap pears to us	 in the light of facts in the appeals	 that it was an essential requirement to be goods	 to be wrapped in paper. Anything required to make the goods marketable	 must form part of the manufacture and any raw material or any materials used for the same would be component part for the end product. In our opinion	 the Tribunal was right in the view it took. There is no ground to interfere in these appeals. Before we conclude	 we must further observe that Shri Bajoria drew our attention to the judgment and order of the Tribunal in Appeal No. ED(SB)A. No. 2734 83C (Collector of Central Excise vs Orient Paper Mills)	 where the appeal has been preferred and in the ' petition in appeal to this court by the revenue under section 35L(b) of the Act	 where the question involved was whether the proforma credit under rule 56A of the Central Excise Rules	 1944 in respect of said 1024 packing and wrapping paper used for packing admissible or not is punishable or not	 the revenue has pleaded that the unit of paper for sale was 'ream ' duly packed in wrapping paper and the real is cured and such real is also wrapped in the wrapping paper. Therefore	 from that statement	 it further appears that such ream or real are wholesale pack ages and are stored in packed condition. If that is the stand of the then it cannot be contended that wrapping paper is not integral part of the manufacture. If that is so	 any material utilised must be component part of the raw material used or consumed in the finished products. Apart from that	 under rule 56A of the Rules	 the assessee would be entitled to the benefit of deduction of the duty to be charged on all wrapping papers	 if any. Nothing contrary to the aforesaid was indicated to us by the revenue though asked to do so. In the aforesaid view of the matter	 this question involved in these appeals is really of academic interest. These appeals	 however	 have no merit for the reasons indicated above and are accordingly dismissed without any order as to costs. G.N. Appeals dismissed.

The respondent	 in the first of these appeals	 was manufacturing different varieties of printing paper includ ing wrapping paper failing under Item No. 17 of the erst while Central Excise Tariff. The appellant issued a show cause notice to the Respondent for the alleged violation of Rules 9(1)	 173 F and 173 G of the Central Excise Rules	 1944 in respect of wrapping paper removed outside the Facto ry without payment of Central Excise duty	 and for imposi tion of penalty. Showing cause	 the Respondent contended that the wrapping paper was captively consumed and utilised as component :art of other varieties of paper and as such no duty was payable. Reliance was placed on section 2(f) of the and Notification No. 18A/83 CE dated 9th July	 1983. The Superintendent (Techni cal) having held otherwise	 the respondent preferred an appeal to the Collector (Appeals). The Collector rejected the claim. On appeal	 the Customs	 Excise and Gold (Control) Appellate Tribunal referred to its own decision	 which is the subject matter of the other appeals herein and set aside the order of the Collector. The facts leading to the other appeals are similar	 and the issue involved is the same. The Revenue has filed the appeals under section 35 L of the Central Excises & Salt Act. On behalf of the Revenue	 it was contended that wrapping paper cannot be deemed to be component part because it did not become an integral part of the packed paper. The assessee	 however contended that wrapping paper was raw material or component part of the wrapped paper	 and relied on section 2(f) of the Act which includes any process incidental or ancillary to the 1018 completion of a manufactured product. It was also urged that Revenue had itself considered the stage of wrapped or packed paper as the stage at which goods should be entered in the statutory production register. Dismissing the appeals	 HELD: 1. 'Manufacture ' in the sense it is used in the excise law	 was not complete until and unless wrapping was done. It is the law now that excise is a duty on manufac ture. Manufacture is the process or activity which brings into existence new	 identifiable and distinct goods. Goods have been understood to be articles known as identifiable articles known in the market as goods and marketed or mar ketable in the market as such. The finished goods were cut to size and packed paper which	 according to the Indian standard and trade practice	 consisted of the wrapping paper and the wrapped paper. Duty is levied on goods. As the Act does not define goods	 the legislature must be taken to have used that word in its ordinary	 dictionary meaning. The dictionary meaning of the expression is that to become 'goods ' it must be something which can ordinarily come to the market to be bought and sold and is known to the market as such. The Tribunal found	 and there was material for the Tribunal to do so	 that the market in which articles in question were sold were paper packed and wrapped in paper. Therefore	 anything that enters into and forms part of that process must be deemed to be raw material or component part of the end product and must be deemed to have been used in completion or manufacture of the end product. [1021G H; 1022A D] Bhor Industries Ltd.	 Bombay vs Collector of Central Excise	 Bombay	 ; ; South Bihar Sugar Mills Ltd.	 etc. vs Union of India & Ors. 	 ; ; Union of India vs Delhi Cloth & General Mills Ltd.	 [1963] Suppl. I SCR 586; Union Carbide India Ltd. vs Union of India and Ors. 	 ; Collector of Central Excise	 Baroda vs M/s Ambalal Sarabhai Enterprises	 ; relied on. Processes incidental or ancillary to wrapping are to be included in the process of manufacture	 manufacture in the sense of bringing the goods into existence as these are known in the market	 is not complete until these are wrapped in wrapping paper. Manufacture of goods should normally encompass the entire process carried on by the dealer of converting raw materials into finished goods. Where any particular process	 is so integrally connected with the ultimate production of goods that	 but for that process	 manufacture or processing of 1019 goods would be commercially inexpedient	 article required in that process	 would fail within the expression 'in the manufacture of goods '. [1022E G] Empire Industries Ltd. & Ors. vs Union of India & Ors. 	 ; ; J.K. Cotton Spinning and Weaving Mills Co. Ltd. vs Sales Tax Officer	 [1965] 16 STC 563 (SC); relied on. [1023F] 3. To be able to be marketed or to be marketable	 in the light of facts in the appeals	 it was an essential require ment to be goods	 to be wrapped in paper. Anything required to make the goods marketable	 must form part of the manufac ture and any raw material or any material used for the same would be component part for the end product. Collector of Central Excise vs Jay Engineering Works Ltd.	 ; referred to.