Job work exemption fails where the manufacturer supplies substantial inputs for the finished product.

Assembling starting resistors did not qualify as exempt job work under Notification No. 119/75 where the appellant supplied and used a substantial proportion of the raw materials and inputs for manufacture. The exemption depended on the work being confined to job work in the intended sense; supplying additional articles does not by itself negate that character, but it does so when those materials form an important and substantial element of the finished product. On that basis, the exemption was denied and the duty demand on the final product was sustained.

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Issues: Whether the activity of assembling starting resistors amounted only to job work so as to attract exemption under Notification No. 119/75 dated 30-4-1975, despite the appellant supplying a substantial part of the materials used in the final product.

Analysis: The claim to exemption depended on whether the work was confined to job work in the sense contemplated by the notification. The record showed that the appellant did not merely provide labour and expertise, but also procured and used a substantial proportion of the raw materials and inputs required for manufacture. In such circumstances, the work could not be treated as simple job work where the supplied materials were insignificant. The reasoning followed the principle that supplying additional articles does not by itself destroy the character of job work, but the position changes when those materials constitute an important and substantial element in the manufacture.

Conclusion: The exemption was not available and the duty demand on the final product was sustained in favour of the Revenue.

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