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G.R.SHARMA, A.C.C.UNNI
Steel Authority of India Ltd. – Appellant
Versus
Collector of Central Excise, Raipur – Respondent
Per G.R. Sharma :
The short point for determination in this appeal is whether the appellants are entitled to the concession in terms of Notification No. 281/86.
2. The facts of the case are that the appellants are engaged in the manufacture of steel and various products of steel. They claimed the benefit of Notification No. 281/86. The Department alleged that the benefit under Notification No. 281/86 will be available if the goods are manufactured in a workshop within the factory. The allegation of the Department was that the machine shop of the appellant was a factory by itself and that workshop and a factory are two different and distinct terms cannoting different things. Ld. Collector (Appeals) before whom the appellant filed an appeal held that the terms workshop and factory are two different things - one is the whole and the other is the part within that; that the functional aspects of the two are also different; that in the factory, mainstream of production work takes place whereas in the workshop within the factory some goods are manufactured to keep the mainstream ticking; that the workshop is a utility service and is not a profit making centre; that no sooner the worksh
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