Manufacturing scrap classification defeats duty demand where troughs from cold rolled sheets are wholly consumed in ingot production.

Troughs cut out from cold rolled sheets were treated as scrap wholly used and consumed in the manufacture of ingots, so they merged with the ingots in the same manner as other steel manufacturing scrap. On that basis, and following earlier identical Tribunal decisions, the demand was held unsustainable and the Revenue's appeal failed. The discussion also considered whether Notification No. 75/67 dated 20-5-1967 applied, but the decisive point was the character and end-use of the troughs as manufacturing scrap.

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Issues: Whether the troughs cut out from cold rolled sheets were liable to duty, and whether Notification No. 75/67 dated 20-5-1967 applied.

Analysis: The troughs were found to be made from scrap and were wholly used and consumed in the manufacture of ingots. They merged with the ingots in the same manner as the rest of the steel manufacturing scrap. As the issue had already been decided by the Tribunal in earlier identical matters, the same reasoning governed the present appeal.

Conclusion: The demand was not sustainable and the Revenue's appeal failed.

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