Designing nickel perforated cylinders does not amount to manufacture, so no central excise duty applies.

Affixing design on nickel perforated cylinders was held not to amount to manufacture because the process merely reproduced the earlier tribunal view that designed cylinders from blank nickel perforated cylinders do not create a new product. The prior ratio, left undisturbed by the Supreme Court, was followed, with the result that no central excise duty was leviable on the process.

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Issues: Whether affixing design on nickel perforated cylinders amounts to manufacture so as to attract central excise duty.

Analysis: The process in question was identical to that considered in an earlier tribunal decision, which had held that making designed cylinders from blank nickel perforated cylinders does not amount to manufacture. That view had also been left undisturbed by the Supreme Court. Following that ratio, the present process of affixing design on nickel perforated cylinders was treated as not resulting in manufacture for excise purposes.

Conclusion: The process did not amount to manufacture and no central excise duty was leviable on that basis.

Ratio Decidendi: A process that merely adds design to nickel perforated cylinders, without bringing into existence a new manufactured product, does not amount to manufacture for central excise purposes.

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