Simple fabrication by bending, punching and drilling holes does not amount to manufacture for excise duty.

Simple fabrication of angles and channels by bending, punching and making holes for use in fixing electricity poles did not amount to manufacture for central excise purposes. The Tribunal held that these processes did not bring into existence a new manufactured product, and therefore the clamps, cross axes, D.P. sets and similar items were not chargeable to excise duty. The appeal was allowed with consequential relief.

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Issues: Whether clamps, cross axes, D.P. sets and similar items fabricated in the workshop by bending, punching and making holes in angles and channels amounted to manufacture attracting central excise duty.

Analysis: The Tribunal noted that the items were made only by simple processes such as bending, punching and making holes for specific use in fixing electricity poles. It followed its earlier decisions holding that such processing of angles and channels does not bring into existence a manufactured product liable to excise duty.

Conclusion: The fabricated items did not amount to manufacture and were not chargeable to excise duty; the appeal was therefore allowed with consequential relief.

Ratio Decidendi: Simple fabrication by bending, punching or making holes in materials, without bringing into existence a new manufactured product, does not constitute manufacture for excise purposes.

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