Completion of manufacture is not postponed by buyer testing unless specific orders make testing a condition precedent.

Goods manufactured in the ordinary course are treated as complete when the production process ends and the goods are offered for sale. Buyer inspection or testing before acceptance does not postpone completion of manufacture, and it does not justify non-entry in the RG 1 register unless the goods were made against a specific order requiring production to a particular design and mandatory testing as a condition precedent. On the facts stated, no such specific buyer order or testing condition was proved, so the testing plea was rejected and the duty-related challenge failed.

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Issues: Whether the manufacture of the castings could be treated as incomplete until testing by the buyers was carried out, and whether the absence of such testing justified non-entry in the RG 1 register.

Analysis: The goods were not shown to have been manufactured pursuant to specific buyer orders requiring production to a particular design and mandatory testing before acceptance. The distinction drawn was between tailor-made goods manufactured for a specific order and goods manufactured by the assessee in the ordinary course and thereafter offered for sale subject to buyer inspection or qualitative tests. On the facts, the case fell in the latter category, so the manufacturing process was complete once production was over. Buyer testing did not postpone completion of manufacture, and the plea based on testing could not be accepted in the absence of proof that the goods were made against specific orders requiring such testing.

Conclusion: The manufacture was complete on completion of the manufacturing process, and the assessee's challenge to the duty-related findings failed.

Final Conclusion: The appeal was rejected because the assessee could not establish that testing by buyers was a condition precedent to completion of manufacture.

Ratio Decidendi: Where goods are manufactured in the ordinary course and merely subjected to buyer inspection or testing before acceptance, manufacture is complete when the production process ends and the goods are offered for sale; testing does not postpone completion unless the goods are made against a specific order requiring such testing.

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