Job work exemption for factory processing was upheld where the worker charged only for processing and returned the customer's goods.

Goods manufactured in a factory as job work were held to fall within the exemption notification where the customer supplied the article, the article was returned after processing, and the worker charged only for the work done. The Court rejected the Revenue's narrow reading that the identical article must be returned in the same form after processing, holding that such a construction would defeat the substance and object of the notification. The exemption was intended to relieve job work factories, because the assessable value in such cases is the value of the work done rather than the full value of the article.

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Issues: Whether the respondent was entitled to exemption under the notification for goods manufactured as job work.

Analysis: The notification exempted goods manufactured in a factory as job work where the article was supplied by the customer and returned after processing, with the worker charging only for the work done. The Court held that the Revenue's insistence that the very article must be returned after processing would deprive the notification of its substance. The object of the notification was to relieve factories doing job work, where the assessable value was the value of the work done and not the full value of the article.

Conclusion: The respondent was entitled to the exemption and the appeal failed.

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