PerGowri Shankar :

We are concerned in these two appeals with whether "compounding" of asafoetida amounts to manufacture. Laljee Godhoo and Co. (LG for short) imports raw asafoetida from Afghanistan. Asafoetida is an exudate from the ferula plant, and imported by the appellant in the form of latex. It is thereafter compounded or blended with wheat flour and gum Arabic. The process is described in the show cause notice issued to the manufacturer as follows:

"The gum arabic and wheat flour are blended in the sigma mixers. Filtered water mixed asafoetida is then poured slowly into the mixer over the gum and wheat flour. This gets the product ready. Further the resultant product is given a heat treatment by suction in pipes through which a heater is attached and the moisture is sucked out. The powder is then passed through a hammer mill where it is crushed thoroughly. This powder is then passed through a sieve, which contains magnet balls absorbing any fine iron particles. The compounded asafoetida in powder form is then packed in different grammage bottles. In case of lump form, the gum and wheat flour along with filtered water mixed with asafoetida is poured into the sigma mixer.