Limited machining of cast iron rolls does not create a new product, so classification remains under Tariff Item 25.

Limited machining that merely removes surface defects and confines fine machining to collar portions does not bring a new marketable product into existence. Cast iron rolls therefore remained classifiable as castings under Tariff Item 25 of the Central Excise Tariff and did not shift to Tariff Item 68. The Department's contrary classification was rejected, and the demand based on Tariff Item 68 did not survive.

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Issues: Whether cast iron rolls, after partial machining and limited fine machining at the collar portions, remained classifiable under Tariff Item 25 of the Central Excise Tariff or became assessable under Tariff Item 68.

Analysis: The machining carried out in the manufacturer's factory was found to be only to remove surface defects, with fine machining confined largely to the collar portions. The goods did not emerge as a different product known in the market as machine parts, and the limited machining did not result in manufacture of a new identifiable article. On the facts, the Tribunal accepted that the extent of machining was negligible and that the relied-upon decisions on partial machining of castings were applicable.

Conclusion: The cast iron rolls were correctly classifiable under Tariff Item 25 of the Central Excise Tariff and not under Tariff Item 68; the classification adopted by the Department was rejected.

Final Conclusion: The dispute on classification was resolved in favour of the assessee, and the demand based on Tariff Item 68 did not survive.

Ratio Decidendi: Limited machining that merely removes surface defects and does not bring into existence a new marketable product does not alter the classification of castings as such.

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