1. Heading of the Judgment

M/S Quippo Energy Ltd. vs Commissioner of Central Excise Ahmedabad – II
Citation: 2025 INSC 1130
Civil Appeal Nos.: 9418-9420 of 2016
Date of Judgment: September 19, 2025
Coram: Justice J.B. Pardiwala and Justice K.V. Viswanathan

2. Related Laws and Sections

The judgment primarily interprets and applies the following statutory provisions:

• The Central Excise Act, 1944:
  Section 2(f): The definition of "manufacture". The court's analysis heavily relied on sub-clause (i), which includes "any process incidental or ancillary to the completion of a manufactured product."
  Section 3: The charging section that levies excise duty on goods "produced or manufactured" in India.

• The Central Excise Tariff Act, 1985:
  Note 6 to Section XVI: This note states that for goods falling under this Section, the conversion of an incomplete article into a complete one shall be deemed to amount to "manufacture".
  Heading 8502.2090: The classification heading for "Generating sets with spark-ignition internal combustion piston eng

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