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The said wood preservatives manufactured by the Respondent Company are sold by it and it also itself undertakes treatment of timber with such preservatives. Such treatment is mostly undertaken by the Respondent Company in respect of wood supplied to it for this purpose by its various customers.

The preservative treatment of wood is made by the Respondent Company as per IS : 401-1982. For this purpose the timber is kept in cylindrical vessel. Air and moisture is extracted from the vessel by applying vacuum and thereafter wood preservative (in the form of water containing 5% preservative) is flooded in the vessel and the timber gets soaked in the solution. Such treated timber is then taken out from the vessel. As per assessees, the object of such treatment given to timber with the help of preservatives is to protect it from wood destroying elements, such as, fungus, borers, termites etc. After treatment, wood is subjected to seasoning i.e. drying of timber, which is done to extract and moisture content so that wrapping, bending and cracking tendencies and eliminated.

The preservative shall conform to IS:10013 (Part II-1981). The preservative is specially recommended in heavy termite and marine borers infected areas and in cooling tower timbers when soft rot is the chief deteriorating factor.

As such it is the appellants contention that in terms of the said specifications preservatives treatment of the wood is a part of national effort to conserve the material resources of the country and to achieve their most economic utilization and the same does not equate or regard such treated wood as densified wood.

6. Apart from the above, assessee has also relied upon the following evidences:

[a] Certificate dated 12-2-1992 from the Forest Research Institute:
Treatment with wood preservatives like CCA (ASCU), Creosote, Penmtachlorophenol etc. is given to non-durable timbers to protect the same from attack of biological agencies like fungus, borers, termites etc. Treatment with wood preservatives does not increase the hardness or density of wood. There is no improvement in strength or resistance to chemical or electrical agencies. As a matter of fact, preservatives like CCA, impair strength and electrical resistance.
The wood preservatives manufactured by M/s. ASCU India Limited, are internationally known and dealt with in the market only as preservatives for protecting wood against attacks of fungus, borers, termites etc. Treatment with such preservatives does not result in increasing the density or hardness of wood, neither its mechanical strength nor resistance to chemical or electrical agencies is improved in any way.
[c] Certificate dated 19-2-1992 from Tamilnadu Housing Board:
This is to certify that various ASCU Wood Preservatives are being purchased by us to treat the wood for protecting it from attacks of destructive elements, such as fungus, borers, termites etc. Due to such treatment by using ASCU Wood Preservatives the wood in question neither acquire any increased density or hardness nor such treatment has the effect of improving mechanical strength of the wood or its resistance to chemical or electrical agencies.