Mere cold rolling of duty-paid steel strips is not manufacture, so no second duty can be levied on the finished strips.

Conversion of duty-paid hot rolled steel strips into cold rolled steel strips does not amount to manufacture, so the resulting cold rolled strips are not subject to a fresh levy of duty. The Tribunal applied earlier binding decisions holding that mere cold rolling from duty-paid inputs does not create a new dutiable product, and it accepted that the same principle continued under the new tariff regime. On that settled position, the duty demand on the cold rolled steel strips was set aside, with consequential relief to the assessee.

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Issues: Whether conversion of duty-paid hot rolled steel strips into cold rolled steel strips amounts to manufacture so as to attract fresh duty, and whether duty is payable again on such cold rolled steel strips.

Analysis: The admitted position was that hot rolled steel strips were converted into cold rolled steel strips. The issue was held to be covered by earlier binding decisions that cold rolled strips produced out of duty-paid hot rolled strips do not undergo a process of manufacture and are not again liable to duty. The Tribunal also accepted that the principle applied under the old tariff continued to govern the new tariff regime. In view of that settled position, the matter was not referred back for fresh examination and the other grounds were not gone into.

Conclusion: Conversion of duty-paid hot rolled steel strips into cold rolled steel strips does not amount to manufacture, and no fresh duty is payable on the cold rolled steel strips.

Final Conclusion: The demand of duty on cold rolled steel strips was set aside, with consequential relief to the assessee in accordance with law.

Ratio Decidendi: Where duty has already been paid on the input hot rolled steel strips, mere cold rolling does not constitute manufacture and cannot give rise to a second levy of duty on the resulting strips.

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