Goods themselves cannot pay duty so the person who create the taxable event must discharge the liability which he had created. The liability to pay tax excise duty is always on the manufacturer or producer if goods. There are three types of parties who can be considered as manufacturers.

* Those who personally manufacture the goods in question

* Those who get the goods manufactured by employing hired labour

* Those who get the goods manufactured by other parties

The following have been held to be real manufacturers :

* In case where the factories are leased out, duty liability is on the lessee as he is the person who actually manufactures the said goods

* When goods are manufactured from others by supplying raw material, the duty liability will rest on the person who actually carried out the manufacturing activity and not on the person who supplied the material.

* In the manufacturer is a mere dummy of the customer or supplier of raw material, then the goods are said to be manufactured on behalf of the customers / suppliers and the latter is liable to duty.