Per V.K. Asthana :

These two appeals are against two orders-in-appeal but since they deal with common subject, therefore, they are being considered together by this common order.

2. The short point for consideration is whether slitting, cutting of Jumbo rolls of aluminium foils to obtain smaller size foils of 0.3m width and 9m length, and thereafter winding these on a suitable roll and packing the same as 'house foil' amounts to manufacture or not?

3. Heard Shri K.K. Anand, ld. advocate for appellants and Shri M.P. Singh, ld. DR.

4. Ld. advocate submits that the aforementioned process amounts to manufacture for the following reasons:

A. The process is not confined to mere slitting or cutting of jumbo rolls of aluminium foils. Instead, the foils are cut to shape, that is as per the desired width and length and are then rewound and packed. Thus the process is involving the activities which are more than mere slitting and cutting of Jumbo rolls.

B. The Jumbo rolls of aluminium foils are obtained from market on payment of duty under sub heading 7607.10 as plain rolls, and since then they are cut to shape i.e. of width of approximately 0.3m and length of 9m, therefore, the product so eme