Fabrication of roofing beams and trusses was not manufacture for excise purposes because the items became part of an immovable structure.

Fabrication of beams, trusses and purlins for factory roofing did not amount to manufacture for excise purposes because the steel sections were cut, drilled, punched and assembled at site as parts of an immovable roofing structure. Once affixed, the columns, beams, trusses and purlins became part of the structure and did not emerge as excisable goods merely because fabrication work was performed. The Tribunal also found the cited monovertical crystalliser ruling inapplicable on the facts. Accordingly, the excise demand could not be sustained.

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Issues: Whether fabrication of beams, trusses and purlins for factory roofing structures amounted to manufacture liable to excise duty.

Analysis: The fabricated steel sections were cut, drilled, punched and assembled at site as parts of the roofing structure. The Tribunal followed the principle that columns, beams, trusses and purlins, when fabricated and affixed into the structure, become part of an immovable structure and do not arise as excisable goods merely by reason of fabrication work. The reliance placed on the decision concerning monovertical crystallisers was found inapplicable on the facts.

Conclusion: The activity did not amount to manufacture for excise purposes and the demands could not be sustained.

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