Pipe fittings made from duty-paid pipes were not treated as manufacture, so no further excise duty arose.

Conversion of duty-paid pipes into bevelled bends, reducers and tee pieces was treated as a mere change in shape and size for specific use, not as manufacture under Section 2(f) of the Central Excises and Salt Act, 1944. Because the fittings remained pipes or tubes in substance and continued to perform the same basic function, no new and distinct excisable product arose and further excise duty was not leviable. The later tariff classification did not change this position, since no new definition of manufacture displaced the principle applied from the Supreme Court authority relied on by the Tribunal.

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Issues: Whether bevelled pipe bends, reducer pipe and pipe tee pieces, made out of pipes and commonly known as pipe fittings, amounted to manufacture under Section 2(f) of the Central Excises and Salt Act, 1944 and were liable to duty again.

Analysis: The appeal was decided by following the earlier Tribunal view that conversion of duty-paid pipes into bends, tees and reducers does not create a new and distinct excisable product. The change in shape and size for specific use does not by itself amount to manufacture where the articles remain pipes or tubes in substance and continue to serve the same basic function. The later tariff classification did not alter the position because no new definition of manufacture was introduced to displace the binding principle applied from the Supreme Court's decision relied upon by the Tribunal.

Conclusion: The pipe fittings did not amount to manufactured goods for the purpose of further excise duty, and duty could not be levied again on them.

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