UNION OF INDIA vs HINDU UNDIVIDED FAMILY BUSINESS KNOWN AS RAMLAL MANSUKHRA

The Supreme Court held that under Item 26A(2) of the Central Excise & Salt Act, 1944, excise duty is leviable on circles in any form or size, including uncut circles. The Court rejected the argument that only trimmed circles qualify as circles for duty purposes, affirming that uncut circles are indeed circles as defined by the statute. The Court also clarified that the process of rolling billets into circles constitutes 'manufacture' as per Section 2(f) of the Act, thus supporting the levy of excise duty at all stages of production.