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Issues: Whether tools, cutters and hobs manufactured in the factory and sent outside for tin coating were covered by Rule 57F(4) of the Central Excise Rules, 1944 so that no central excise duty was payable on their removal.
Analysis: Rule 57F(4) authorised removal of inputs as such or after partial processing to a place outside the factory for specified operations, including any other operation necessary for the manufacture of the final product, and for return for further use in manufacture. The tools were sent out for tin coating to extend their life and were used in the manufacture of the final product. The fact that the goods had acquired the character of tools did not take them outside the scope of Rule 57F(4), and the absence of further processing after return did not negate the applicability of the rule. The Revenue's objection to exemption under Notification No. 67/95-C.E. also did not survive in view of the permitted removal under Rule 57F(4).
Conclusion: The removal of the tools for tin coating was covered by Rule 57F(4), and no central excise duty was payable at the time of such removal.
Ratio Decidendi: Where goods manufactured in the factory are sent outside for an operation that extends their utility and remains connected with manufacture of the final product, their removal is permissible under Rule 57F(4) and is not liable to duty at the stage of clearance for that operation.
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