Circular No. 19/19/94-CX dated 9/2/94
Subject: Central Excise - Galvanisation - Whether it amounts to manufacture or not
Representations have been received that in certain Collectorates process of galvanisation has been treated as a manufacturing activity
within the meaning of Section
2(f) of the Central Excises and Salt Act, 1944.
2. The Board had issued a Circular No. 25/90-CX.4 dated 11.7.1990 wherein it was clarified that the galvanised pipes and tubes also would be covered the expression Tubes and Pipes. This Circular was based on Supreme Court
judgments in the case of Gujarat Steel Tubes Limited v. the State of Kerala a Others (1989) (23) (ECR-161-SC).
GEGAT and Gujarat High Court in the following two decisions have also held that
Galvanisation does not amount manufacture.
i. CCE v. Kamani Engineering Corporation Limited 1989 (39) 437(Tribunal).
ii. Zaverchand Gaekwad Private Limited v. UOI -1992 (61) ELT-225 (Gujarat).
3. In view of the above, it is clarified that galvanisation does not amount to manufacture within the meaning of Section 2 (f) of the Central Excises and Salt
Act, 1944.
Sd/-
(Arvind Singh)
Deputy Secretary the Government of India
F.No.l39/25/92-CX.4
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