1998 (8) TMI 342

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..... per : Gowri Shankar, Member (T)]. The appellant was a manufacturer of, among other goods, conveyor roller. It received for repair consignments of rollers from Gujarat Mineral Development Corporation which had been originally supplied by the manufacturer Elecon Engineering Co. After carrying out the processes required by the customer the appellant returned the rollers without paying duty on .....

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..... ller were subjected to did not amount to manufacture. Reliance is placed upon the decision in Shriram Refrigeration Industries Ltd. v. C.C.E. - 1986 (26) E.L.T. 353. It is also contended that the question as to whether the duty paying documents accompanied the goods was not raised in the notice and therefore could not have been raised before the Collector (Appeals) and that there is no question of .....

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..... the processes amount to manufacture and not reconditioning. Even without going into the details to the decisions cited it will be difficult to hold that these processes amounted to manufacture in the sense that what was cleared from the factory was something completely different from what was received. 5. In any event, the decision of the Tribunal which the appellant relies upon and the circula .....

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