Affixing ticklies on taps, valves and cocks is not manufacture because no new commodity emerges.

Affixing ticklies on bought-out taps, valves and cocks does not amount to manufacture because the process does not bring into existence a new product with a different name, nature or use. Mere attachment of a brand-related item, without a transformative manufacturing operation, fails the statutory test of manufacture. The Revenue's challenge therefore fails on the ground that the goods remain the same commodity after the process.

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Issues: Whether affixing ticklies on bought out taps, valves and cocks amounts to manufacture.

Analysis: The process of affixing ticklies did not bring into existence any new substance or a product different in name, nature or use. Mere fixing of a brand-related item on taps, valves and cocks, without any manufacturing operation that transforms the goods into a new commodity, does not satisfy the test of manufacture under the relevant statutory provision.

Conclusion: Affixing ticklies on taps, valves and cocks does not amount to manufacture and the Revenue appeal fails.

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