Siddhartha Tubes Ltd vs Commissioner Of Customs & Central ...

The Supreme Court addressed whether galvanization constitutes a manufacturing process under Section 2(f) of the Central Excise Act, 1944. The Court held that the process of galvanization does not amount to manufacture as the m.s. pipes were already marketable after hydro testing and other processes in the tube mill section. Consequently, the value of galvanization could not be included in the assessable value for excise duty, affirming the appellant's claim against the department's show-cause notice regarding under-invoicing.