The appellant, M/S Alupro Building Systems Pvt. Ltd., a construction contractor, imported pre-coated Aluminium Composite Panels (ACPs) and subjected them to cutting, routing, and grooving at its premises before fixing them on building facades. The Revenue issued a Show Cause Notice demanding excise duty on the ground that these processes amounted to 'manufacture' under Section 2(f) of the Central Excise Act, 1944. The CESTAT had ruled in favour of the appellant, holding that no new product emerged and the Revenue had not discharged its burden of proving marketability; however, the High Court of Karnataka reversed this, holding that cutting, grooving, and routing of ACPs resulted in a commercially distinct new product amounting to manufacture. The Supreme Court took up the appeal to examine the scope of 'manufacture' under Section 2(f) of the Act, 1944, and the jurisdictional question of whether the High Court's reference under Section 35G was maintainable.