Slitting jumbo tissue paper rolls into smaller sizes is not manufacture when commercial identity remains unchanged.

Cutting or slitting jumbo tissue paper rolls into smaller sizes did not create a product with a different commercial identity, so the activity failed the twofold test for manufacture. The process was therefore treated as non-manufacturing, and the Revenue's appeal was rejected.

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Issues: Whether cutting jumbo paper rolls into smaller sizes amounts to manufacture.

Analysis: The process of slitting or cutting jumbo rolls of tissue paper into smaller sizes did not bring into existence a product with a different commercial identity. The activity also failed the twofold test for manufacture.

Conclusion: The process did not amount to manufacture and the Revenue's appeal was rejected.

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