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Issues: Whether wire nails manufactured by the appellants from wire supplied by their customer and returned to the customer on job-work basis were entitled to exemption under Notification No. 119/75-C.E. dated 30-4-1975.
Analysis: The exemption was held to depend on whether the goods were received from the customer, subjected to a manufacturing process, and returned after such processing. It was not essential that the article received and the article returned should bear the same trade description. The fact that wire was converted into wire nails did not by itself exclude the benefit of the notification, since the processing was carried out on materials supplied by the customer and the processed product was returned to the same customer. Prior decisions and administrative interpretation supported this view.
Conclusion: The appellants were entitled to the benefit of Notification No. 119/75-C.E. dated 30-4-1975, and the demand based on denial of that exemption was not sustainable.
Ratio Decidendi: For job-work exemption under the notification, identity of trade nomenclature between input and output is not ative where the supplied goods are processed and returned to the supplier after manufacturing.