Fabrication of steel structures at site held to be an intermediate process, not manufacture for central excise purposes.

Fabrication of steel structures such as trusses, beams, purlins and columns by cutting, drilling, welding and site erection was treated as an intermediate process in the course of erection work, not as manufacture. The Tribunal applied its earlier ruling that processing duty-paid steel materials at site in this manner does not, by itself, bring the resulting structures within central excise liability. On that basis, the fabricated goods were held not to be excisable manufactured products, and the duty demand and impugned order were set aside.

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Issues: Whether fabrication of steel structures such as trusses, beams, purlins, columns and similar items by cutting, drilling, welding and erection amounted to manufacture and attracted central excise duty.

Analysis: The dispute concerned fabricated steel structures made from duty-paid steel materials supplied by the appellants and processed at site through cutting to size, drilling holes, welding and erection by bolts and welding. The Tribunal treated the issue as covered by its earlier decision holding that such fabrication processes are only intermediate processes and do not amount to manufacture.

Conclusion: The fabricated goods were not liable to be treated as excisable manufactured products, and the appeal succeeded.

Final Conclusion: The duty demand and the impugned order were set aside.

Ratio Decidendi: Fabrication of steel structures by cutting, drilling, welding and similar site processes, when undertaken as part of erection work, is an intermediate process and does not by itself amount to manufacture for central excise purposes.

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