The dispute concerned whether the activity carried out by M/s Xerox India Ltd. at its warehouses in Hyderabad and Rampur—grouping and fitting together imported modules of photocopier machines in CKD/SKD condition to meet customer specifications—amounted to 'manufacture' under Section 2(f) of the Central Excise Act, 1944, read with Note 6 to Section XVI of the Central Excise Tariff Act, 1985. The Revenue (Commissioner of Central Excise) demanded excise duty of approximately Rs. 17.86 crore for the period April 2002 to November 2006, contending that a new marketable product came into existence through the assembly process. The CESTAT (South Zonal Bench, Bangalore) set aside the Commissioner's order, finding that no actual assembly or conversion of an incomplete machine into a complete machine took place at the warehouse, and that the goods were imported, classified, and assessed to customs duty and CVD as complete machines under Tariff Heading 8471. The Supreme Court was called upon to examine whether the Tribunal's findings were correct on this question of law and fact.