In the instant case, the assessee received duty paid printed/unprinted/plastic plain laminated films of 500mm to 700mm width on jumbo rolls, classified under CET sub-heading 3920.38 from their factory at Mahad, under cover of invoices evidencing payment of duty, rewound them on slitter-cum-rewinder machine and slit them into widths of 250mm, 285mm, 300nim etc. and the slit films also fall for classification under CET sub-heading 3920.38. The Mahad factory also clears plastic laminated films in jumbo rolls to independent customers.

Since, the issue was under tremendous ambiguity and the lower bench of tribunal (CESTAT) has referred the matter to the Larger Bench to decide the issue.

After considering the various decisions of the honorable Supreme Court, larger bench of CESTAT has held that the mere slitting and cutting of duty paid rolls into smaller rolls is not a manufacturing activity and not liable to excise duty.

(See: ANIL DANG Versus COMMISSIONER OF CENTRAL EXCISE, VAPI - 2007 -TMI - 1393 - CESTAT, MUMBAI)

Manufacturing classification: mere slitting of duty-paid laminated film rolls is not manufacturing and not excisable. After considering authorities and earlier ambiguity, the Larger Bench held that mere slitting and cutting of duty-paid plastic laminated jumbo rolls into smaller rolls does not amount to manufacturing and therefore does not attract excise duty on the resultant slit rolls.