Manufacture under job-work provisions includes ancillary processing; goods were not fully manufactured at the job worker's premises.

Processes carried out by a raw material supplier and a job worker did not result in fully manufactured goods at the job worker's premises because the final manufacturing sequence was completed only after de-flashing, hardness and thickness testing, and inspection by the supplier. The Tribunal's factual finding that the job worker performed only part of the processing, while the last steps necessary to make the goods marketable were undertaken by the primary manufacturer, was accepted. Applying the statutory meaning of manufacture and the principle that incidental or ancillary processes form part of manufacture, the Court upheld the Tribunal's treatment of the activity as manufacture under the job-work provisions and found no substantial question of law.

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Issues: Whether the processes carried out by the raw material supplier and the job worker resulted in fully manufactured goods at the job worker's end, and whether the goods returned by the job worker were liable to duty as such.

Analysis: The Court accepted the Tribunal's factual assessment that the manufacturing sequence was completed only after the goods were subjected to de-flashing, testing for hardness and thickness, and inspection by the raw material supplier. The Tribunal had also found that the job worker performed only part of the processing and received job charges, while the final steps necessary to make the goods marketable were undertaken by the primary manufacturer. Relying on the statutory definition of manufacture and the principle that processes incidental or ancillary to production fall within manufacture, the Court held that the Tribunal had correctly treated the activity as a manufacturing process under the relevant job-work provisions.

Conclusion: The goods were not fully manufactured at the job worker's premises, the Tribunal's view was correct, and no substantial question of law arose for consideration.

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