Fabrication of steel roof structurals was held not to amount to manufacture for excise duty purposes.

Fabrication of steel roof structurals such as trusses and purlins from steel angles, plates and similar raw materials was analysed as an activity involving cutting, drilling, riveting and assembling of components for roof construction. The settled view applied was that this process does not create a new and distinct article, so it does not amount to manufacture for excise purposes. Mere inclusion of the items in Tariff Heading 7308 was held insufficient, by itself, to make the fabricated items dutiable goods under the Central Excise Tariff.

---

---

Issues: Whether fabrication of steel roof structurals such as trusses and purlins from steel angles, plates and similar raw materials amounts to manufacture and attracts excise duty under Tariff Heading 7308.

Analysis: The activity consisted of cutting, drilling, riveting and assembling of structural components for roof construction. The settled view relied upon was that such fabrication does not bring into existence a new and distinct article. Mere mention of the items in Tariff Heading 7308 was held to be insufficient by itself to treat them as manufactured goods exigible to duty.

Conclusion: The activity did not amount to manufacture and the goods were not dutiable under the Central Excise Tariff; the appeal succeeded.

---