Principal-to-principal job work shifts excise manufacturer status to the job workers, not the customer.

Storage tanks and prefabricated steel structures manufactured by independent job workers on a principal-to-principal basis were treated as goods manufactured by the job workers for central excise purposes. Where the appellant supplied raw material, designs and specifications, and there was no allegation or evidence that the arrangement was anything other than principal to principal, the settled view applied that the job workers are the manufacturers. Excise duty was therefore not fastened on the appellant, and liability lay with the job workers.

---

---

Issues: Whether storage tanks and prefabricated steel structures manufactured through job workers on a principal to principal basis were liable to central excise duty in the hands of the appellant or in the hands of the job workers.

Analysis: The goods were manufactured by job workers from raw material, designs and specifications supplied by the appellant. There was no allegation or evidence that the dealings between the appellant and the job workers were not on a principal to principal basis. The settled view applied in prior decisions was that where manufacture is carried out by independent job workers on such terms, the job workers are to be treated as the manufacturers and the customer is not liable to pay the duty.

Conclusion: The duty liability was not fastened on the appellant and the job workers were the manufacturers for excise purposes.

---