Manufacture under central excise law was not established for cutting, punching and galvanising processed steel components.

Cutting, drilling, punching, painting and galvanising of processed channels, angles and plates were treated as processes that do not, by themselves, amount to manufacture under central excise law when applied to steel components for specified use. The reasoning followed earlier Tribunal and Supreme Court authorities holding that cutting, punching, straightening and galvanising do not necessarily create a new and distinct product. On that basis, the processes were held not to constitute manufacture, and the Revenue's appeal was rejected.

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Issues: Whether cutting, drilling, punching, painting and galvanizing of processed channels, angles and plates amounts to manufacture under central excise law.

Analysis: The processes in question were found to be covered by earlier Tribunal and Supreme Court authorities holding that cutting, punching, straightening and galvanising of steel channels, angles, plates and bars for use as specified components do not, by themselves, bring about manufacture. The reasoning accepted that such operations do not necessarily result in a new and distinct product.

Conclusion: The processes did not amount to manufacture, and the Revenue's appeal was rejected.

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