treating the ordinary water and converting the same into treated water. In that view of the matter, as per the Department, there is no commodity manufactured as understood in terms of Section 2-F of the Central Excise Act, 1944 (for short ‘the Act’). The contention of the appellant all through is that the ordinary water and also the mineral laden water, on treatment with the machinery manufactured by the appellant, is different and distinct in character and though in general terms, it may remain as water but in the specific industry, the same is accepted as distinct product. For example; sewerage water converted into potable water, hard water being converted into soft water, the regular well water and tap water after treating the same by the reverse osmosis process being sold as pure drinking water. He would assert that the machinery that is being manufactured by the appellant is capable of producing treated water and in a given case supplying treated water can be envisaged on industrial scale. He would submit that the contention, which has been urged that the appellant’s machinery that is being manufactured by the appellant is capable of production of a commodity, distinctly recognised as treated water has not been considered by the authorities concerned and no finding contra has been given either.
