Exemption for steel wires upheld where wire rods were treated as an intermediate stage in a continuous billet-based process.

Steel wires manufactured from wire rods were treated as eligible for exemption because wire rods were themselves produced from billets and the billet-to-wire rod-to-wire sequence was regarded as a continuous manufacturing process. Exemption could not be denied merely because wire rods were an intermediate stage. A later amendment to the notification and the Board's circular were consistent with this interpretation and supported the view previously taken by the Tribunal, so the denial of exemption was unsustainable.

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Issues: Whether steel wires manufactured from wire rods could be treated as having been made from billets so as to qualify for exemption under the notification.

Analysis: Wire rods are themselves manufactured from billets, and the manufacturing stream from billets to wire rods and then to steel wires was treated as a continuous process. The exemption could not be denied merely because wire rods appeared as an intermediate stage. The subsequent amendment to the notification and the Board's circular also supported this interpretation and reflected acceptance of the Tribunal's earlier view on the same question.

Conclusion: The steel wires were eligible for exemption under the notification, and the denial of exemption was unsustainable.

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