Full Judgment
The Appellants have claimed the benefit of Notification No. 53/97-Cus.
which provided that the exemption would be available to goods which on importation into India are used for the purpose of articles within 100% Export Oriented Unit. Shri B.L. Narasimhan, learned Advocate, fairly mentioned that the Appellate Tribunal in the case of CCE, Surat-II v.P.S.L Corrosion Control Limited, 2003 (151) E.L.T. 439 (T) has held that the process of coating of steel bars/rebars with epoxy powder does not amount to manufacture as no different commercial commodity comes into existence. In view of this fact, the benefit of Notification No.53/97-Cus. will not be available to the Appellants. Accordingly, the appeal is rejected.