Galvanizing of Chapter 72 goods was not manufacture during the relevant period, so excise duty did not apply.

Galvanizing of goods under Chapter 72 did not amount to manufacture during the impugned period because the statutory amendment treating galvanization as manufacture applied only from 08.04.2011 under Chapter V of the Finance Act, 2011. As that amendment did not cover the relevant period, the activity remained outside the scope of manufacture for excise purposes, and no excise duty was payable on it.

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Issues: Whether galvanizing of goods falling under Chapter 72 during the impugned period amounted to manufacture so as to attract excise duty.

Analysis: The only surviving dispute concerned galvanizing of goods falling under Chapter 72, on which service tax had been paid. The relevant legal position noted was that galvanization was treated as manufacture only with effect from 08.04.2011 by Chapter V of the Finance Act, 2011. For the impugned period, galvanizing of Chapter 72 goods was not covered by that amendment and therefore did not amount to manufacture.

Conclusion: The activity did not amount to manufacture during the impugned period and no excise duty was payable on it.

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