Tariff classification of runners and risers turned on their status as manufacturing by-products, not ingots, securing exemption.

Runners and risers arising during the manufacture of steel ingots were treated as materials used in the making of ingots, not as ingots themselves. The relevant exemption notification indicated that such by-products, like skull scrap, were distinct from finished ingots, and the record did not show that trade or industry regarded them as ingots or as steel melting scrap during the material period. Later administrative views and subsequent statutory references were held irrelevant to that period. On that basis, runners and risers were not chargeable under Tariff Item 26, and the exemption claim was accepted in favour of the assessee.

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Issues: Whether runners and risers arising during the manufacture of steel ingots were covered by Tariff Item 26 and entitled to exemption under Notification No. 53/80 dated 13.05.1980.

Analysis: The notification treated skull scrap and runners and risers arising in the course of manufacture of steel ingots with the aid of electric furnace as materials for manufacture of ingots, showing that they were not to be equated with ingots themselves. The record did not establish that runners and risers were regarded in trade and industry as ingots or as steel melting scrap. The later administrative view and subsequent statutory references were held irrelevant for the material period. In the absence of evidence that the material was a manufactured product covered by the tariff entry during the relevant time, the demand could not be sustained.

Conclusion: Runners and risers were not chargeable under Tariff Item 26 for the relevant period and the exemption dispute was decided in favour of the assessee.

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