In re Shri M C Patel & Sons LLP (CAAR Mumbai)
Summary: The Customs Authority for Advance Rulings, Mumbai considered an application filed by M/s Shri M C Patel & Sons LLP seeking an advance ruling on whether threshing, sieving, cleaning and sizing of dried broken raw tobacco leaves followed by packing in bulk packs amounted to “manufacture” under Section 2(f) of the Central Excise Act, 1944 and consequently attracted Central Excise duty. The ruling was issued as CAAR/Mum/ARC/72/2026-27 dated 24.08.2026. The supplied ruling records that the application was received on 30.01.2026 under Section 23C of the Central Excise Act, 1944. The applicant was a resident LLP and relied upon Notification No. 11/2015-Central Excise (N.T.), dated 01.03.2015, which specified a resident firm as a class of persons for advance ruling and included a limited liability partnership within the meaning of “firm”.
The applicant, incorporated as an LLP on 13.06.2025, stated that it had previously operated as a sole proprietorship under the name M C Patel & Sons. It procured dried broken raw tobacco leaves from farmers in bulk packs. The farmers generally sun-dried the leaves, removed stalks and stems, cleaned them and packed them in bulk for sale. The applicant’s process consisted of unpacking the bulk packs, feeding the tobacco into a GLT machine for threshing, cleaning and sizing, and subsequently packing the processed tobacco in bulk bags of approximately 25 kg to 40 kg. No new ingredient, material or substance was added.
