Mere reduction in size is not manufacture for cold rolled strips under Central Excise law, and the assessee succeeded.

Mere reduction in size of cold rolled strips does not amount to manufacture under Section 2(f) of the Central Excise Act because the goods continue to remain cold rolled strips after resizing. The prior revisional view on an identical issue was followed, and the fact that the original supplier had paid a lower duty under an interim injunction did not change the character of the material once the correct duty was later paid. The revision application was allowed in favour of the assessee.

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Issues: Whether mere reduction in size of cold rolled strips amounts to manufacture under Section 2(f) of the Central Excise Act, and whether the revision application was liable to be allowed.

Analysis: The goods cleared as cold rolled strips remained strips even after being reduced to smaller dimensions. The earlier revisional view on an identical issue held that such reduction in size does not bring about manufacture within the meaning of Section 2(f). The fact that the original supplier had paid a lower rate of duty under an interim injunction did not alter the character of the raw material, especially when the correct duty was subsequently paid and there was no basis to treat the goods as anything other than cold rolled strips.

Conclusion: Mere reduction in size of cold rolled strips does not amount to manufacture under Section 2(f) of the Central Excise Act, and the revision application was allowed in favour of the assessee.

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