Processing of TC sets, DP sets and tower parts did not amount to manufacture; goods remained non-excisable.

Punching, drilling and similar processing of TC sets and DP sets did not amount to manufacture, so they were not liable to central excise duty. For tower parts and out-door structures, cutting materials to length and making holes did not bring into existence a new product distinct from the original angles, beams and channels, so these items were also treated as non-excisable. The appeal was rejected and the order holding the goods as non-excisable was upheld.

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Issues: Whether TC sets, DP sets, tower parts and out-door structures processed in the factory were excisable goods liable to central excise duty.

Analysis: The Tribunal relied on the earlier finding in the respondents' own case that punching, drilling holes and similar processes undertaken on TC sets and DP sets did not amount to manufacture and therefore did not attract duty. For tower parts and out-door structures, the Tribunal noted that the materials were cut to required lengths and holes were made thereon, but no new product different from the original angles, beams and channels came into existence. On that reasoning, and in light of the earlier view on structurals, the items were held not to be excisable goods.

Conclusion: The appeal was rejected and the order holding the goods as non-excisable was upheld.

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