Re-drawing copper wire from copper rods is not manufacture, as settled appellate and Supreme Court authority confirms.

Re-drawing copper wire of less than 6 mm from copper rods was treated as not amounting to manufacture, because the settled position and the appellate and Supreme Court rulings relied on supported that view. No contrary authority was produced to displace the existing legal position. The Revenue's challenge therefore failed.

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Issues: Whether re-drawing of copper wire of less than 6 mm from copper rods amounts to manufacture.

Analysis: The impugned order was based on the settled position that re-drawing of copper wire of less than 6 mm from copper rods does not amount to manufacture. No contrary authority was cited to dislodge that view, and the prior appellate and Supreme Court rulings relied upon by the Commissioner (Appeals) supported the same conclusion.

Conclusion: Re-drawing of copper wire of less than 6 mm from copper rods does not amount to manufacture, and the Revenue's appeal fails.

Ratio Decidendi: Re-drawing of copper wire of less than 6 mm from copper rods, by itself, is not manufacture.

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