Corrugation as manufacture under Central Excise law creates a new commercial product and attracts duty.

Corrugation of galvanized iron and steel sheets is treated as manufacture under Central Excise law where the process creates a commercially distinct product with a different identity and use. The Tribunal relied on the interpretation of manufacture under Section 2(f) of the Central Excise Act and the view that corrugation does not merely preserve the original character of the sheets but brings into existence a new commercial commodity. On that basis, corrugated sheets were held liable to central excise duty.

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Issues: Whether corrugation of galvanized iron and steel sheets amounts to manufacture under the Central Excise law and attracts central excise duty.

Analysis: The dispute turned on whether corrugation merely preserves the character of the original sheets or results in a commercially distinct product. The Tribunal noted that earlier sales tax rulings treating corrugated sheets as continuing to remain iron and steel were distinguished by the Punjab and Haryana High Court in Hansa Metallic Ltd., which, after considering the definition of manufacture under Section 2(f) of the Central Excise Act, held that corrugation of plain metallic and galvanized sheets brings into existence a new commercial product with a different identity and use. The Tribunal also relied on its own earlier decision taking the same view in respect of corrugation of coils.

Conclusion: Corrugation amounts to manufacture; the corrugated sheets are liable to central excise duty.

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