In Brief
Universal Ferro & Allied Chemicals Ltd transferred Manganese Ore to be processed into Silicon Manganese. The Central Excise authorities disputed whether this transaction qualified as a 'sale' under excise law and whether exemption applied. The Supreme Court held that 'sale' under the Central Excise Act must be interpreted according to the Act's own statutory definition, not the Sale of Goods Act. Since goods were transferred for valuable consideration in ordinary trade, they constituted a 'sale' attracting exemption. The Court emphasized that different statutes with different purposes cannot have definitions mechanically applied across them. The appeal was dismissed, upholding the exemption notification applicability."
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