Slitting and packing of jumbo rolls was not manufacture before the later trade notice took effect.

Cutting and slitting jumbo rolls of sensitised polyester films into smaller rolls, together with packing under special light conditions, was treated as falling outside manufacture for the relevant period. The Tribunal applied its earlier view that such processing does not amount to manufacture under Section 2(f) of the Central Excises and Salt Act, 1944, and held that Board Circular No. 119/1/88-CX. III and Trade Notice No. 18/89 operated in different periods. It further held that the later trade notice did not retrospectively alter the earlier circular, so the disputed process remained non-manufacture before the trade notice became operative.

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Issues: Whether slitting of jumbo rolls of sensitised polyester films into smaller rolls of required size, along with packing under special light conditions, amounted to manufacture.

Analysis: The Tribunal followed its earlier decision holding that cutting, slitting and packing of jumbo rolls does not amount to manufacture. It noted that the Board's Circular No. 119/1/88-CX. III dated 05.09.1988 and Trade Notice No. 18/89 dated 06.03.1989 operated in different periods, and that the trade notice did not retrospectively amend the earlier circular. Since the period in dispute was prior to the effective date of the trade notice, the process remained outside the scope of manufacture under Section 2(f) of the Central Excises and Salt Act, 1944.

Conclusion: The process of slitting and packing the jumbo rolls did not amount to manufacture for the relevant period, and the appeal was dismissed.

Ratio Decidendi: For the period prior to the operative date of the later trade notice, cutting, slitting and packing of jumbo rolls does not constitute manufacture, and a subsequent trade notice does not operate retrospectively unless it clearly so provides.

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