Commissioner Of Central Excise vs Indian Aluminium Co. Ltd

The Supreme Court addressed whether zinc dross and flux skimming are excisable articles under the Central Excise Tariff Act. The Court held that dross, previously classified as waste, is now considered goods due to its marketability and high aluminium content, thus subject to excise duty. The judgment followed precedents set in Union of India v. Indian Aluminium Co. Ltd. and Collector of Central Excise, Patna v. Tata Iron & Steel Co. Ltd., affirming the Tribunal's decision that dross is not a manufactured product but a by-product of manufacturing.