Galvanizing steel products is treated as manufacture, triggering central excise duty with interest and penalty consequences.

Galvanizing of steel products is treated as manufacture under jurisdictional pronouncements and Chapter Note 4 of Chapter 73 of the Central Excise Tariff Act, 1985. On that basis, the activity is considered to attract central excise duty. Where duty is not paid in time, interest and penalty may also follow as consequential liabilities. The stated position confirms that galvanizing steel items is not a mere processing step for excise purposes, but a manufacturing activity with duty implications.

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Issues: Whether galvanizing of steel products amounts to manufacture and therefore attracts central excise duty, interest, and penalty.

Analysis: The activity of galvanizing steel items was found to be covered by jurisdictional pronouncements holding it to be manufacture. Chapter Note 4 of Chapter 73 of the Central Excise Tariff Act, 1985 was relied upon to treat the activity as manufacture. On that basis, the liability to pay duty followed, and the failure to pay duty in time justified the levy of interest and penalty.

Conclusion: Galvanizing amounts to manufacture, and the demand of duty, interest, and penalty was upheld against the assessee.

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