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3. The respondents have contested the aforesaid contentions. On merits, it is submitted that the Chapter note I of Chapter 54, does not help and support the contentions of petitioners. Reliance is placed on the definition of the term 'manufacture' in the definition clause 2(f) of the Central Excise Act, 1944 (Act, for short) to controvert the first contention. To draw support, the respondents have referred to Plasmac Machine Mfg. Co. Pvt. Ltd. vs. Collector of Central Excise, 1991(51) ELT 161 (SC); Elson Machines Pvt. Ltd. vs. CCE, 1998(38) E.L.T. 571 (SC); Faridabad CT Scan Centre Vs. D.G. Health Services, 1997(95) ELT 161 (SC); B.J. Akkara, Col. (Retd.) vs. Govt. of India, 2007(207) ELT 3 (SC); Sharp Industries Ltd. vs. Commissioner of Central Excise, (2005) 7 SCC 676; Rajasthan State Electricity Board & Ors. vs. Laxman Lal & Ors., 1991 Supp (2) SCC 531; State of Maharashtra vs. Digambar, (1995) 4 SCC 683; Union of India vs. Delhi Cloth and General Mills Co. Ltd., AIR 1963 SC 791; Sterling Foods vs. State of Karnataka, AIR 1986 SC 1809; Aditya Mills Ltd. vs. Union of India, 1988 (37) ELT 471 (SC) and Collector of Central Excise, Bombay vs. K.W H Heliplastics, 1998 (97) ELT 385 (SC). It is submitted that the order of the Tribunal in GPL Polyfils Ltd. (supra), is per incuriam and cannot be treated as a precedent. On the question of the circular and the right of the Board to issue circulars, it is submitted that the same has been validly issued under Section 37B of the Act.