Exemption under iron and steel notification denied where cut ends of M.S. flats did not fit the specified sub-item.

Sub-Item 8 was confined to pieces of iron and steel given a rough shape by rolling or forging, and did not extend to pieces cut off from bars, rods or flats from the main item. Ends of M.S. flats purchased from scrap dealers and used as inputs did not satisfy that description, so they could not qualify for exemption under Notification No. 208/83. A separate argument that the goods might fall under another sub-item was not considered because it was raised for the first time at the hearing.

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Issues: Whether ends of M.S. flats used as inputs could be treated as goods falling under Sub-Item 8 so as to qualify for exemption under Notification No. 208/83.

Analysis: The exemption depended on the inputs falling within the specified sub-item. The Court held that Sub-Item 8 covers pieces of iron and steel given a rough shape by rolling or forging, not pieces cut off from bars, rods or flats from the main item. The ends of flats purchased from scrap dealers and used by the assessee did not answer that description. The alternative contention that they might fall under another sub-item was not entertained as it was raised for the first time at the hearing.

Conclusion: The ends of M.S. flats did not fall under Sub-Item 8 and the assessee was not entitled to exemption under the notification.

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