Withdrawn circulars could not sustain duty demand on coil-to-sheet job work, so the revenue appeal failed.

Duty demand on job-work conversion of coils into sheets was not sustainable because it rested on Board circulars that had already been withdrawn or quashed following earlier judicial decisions. The Tribunal noted that the circular forming the basis of the demand had ceased to operate and that the revenue's challenge to the adverse High Court view had failed. On that footing, the alleged manufacture basis could not support the demand, and the revenue's appeal was dismissed.

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Issues: Whether the process of cutting coils into sheets on job work basis amounted to manufacture so as to sustain the duty demand, and whether the demand could survive when the circular forming its basis had been withdrawn or quashed.

Analysis: The demand was founded on Board circulars which had already been withdrawn or quashed in the light of earlier judicial decisions. The Tribunal noted that the circular relied upon for the demand had ceased to operate and that the revenue's challenge against the adverse High Court view had not succeeded. In that background, the basis for the duty demand was not sustainable.

Conclusion: The demand could not be upheld and the revenue's appeal was dismissed.

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