M/S Gujarat Industries & Ors vs Commr.Of Central Excise-I,Ahmedabad

The Supreme Court addressed whether the cold-rolling process undertaken by the assessee constitutes 'manufacture' under Section 2(f)(i) of the Central Excise Act, 1944. The Court upheld the CESTAT's ruling that cold-rolling does amount to manufacture as per Chapter Note 4 of Chapter 72 of the Central Excise Tariff Act, 1985, despite the absence of reference in the show cause notice. The Court also confirmed the invocation of the extended period of limitation under Section 11A for demanding duty and imposing penalties on the assessee.