I.J. Rao, Member (T)

1. The appellant company was fabricating columns, purlins, bracings, rafters and other items required for erection. The fabrication was out of duty paid iron and steel products such as plates, angles etc. by subjecting them to the process of cutting, welding revetting etc. The Assistant Collector held that the process of conversion of iron and steel products into columns etc. amounted to a process of manufacture since the resultant goods had a distinct name, character and use, different from the raw materials. The full details of the matter were very well recorded by the Assistant Collector in his order. The following portion of his order is reproduced in view of its detail :-

"The raw materials used in fabrication are standard profiles and plates as supplied by rolling mills of Steel Plants i.e. joists, channels, angles and plates of various sizes, length and thickness as required. The fabrication of steel structure generally involves the following processes. They are partly/wholly completed at their factory and the balance operations are completed at the site.

(i) Templating.

(ii) Cutting to size by guillotine or oxy-planer.

(iii) Drilling of holes.

(iv) Assem