Manufacture test under central excise: merely loading duty-paid ribbons into spools or cartridges is not manufacture.

Putting duty-paid inked ribbons into spools, cassettes or cartridges did not amount to manufacture because the ribbons underwent no physical or chemical change and retained the same character, identity and end use. Applying the settled test for manufacture, no new and distinct commercial commodity came into existence, so the process fell outside section 2(f) of the central excise law. The tariff phrase "whether or not" was treated as covering ribbons supplied on spools or in cartridges as excisable goods, but not as creating a separate act of manufacture. The resulting goods were therefore not liable to central excise duty.

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Issues: Whether putting duty-paid inked ribbons into spools, cassettes or cartridges amounted to manufacture under the central excise law, so as to attract duty on the resulting product.

Analysis: The process undertaken was only putting duty-paid inked ribbons into spools, cassettes or cartridges. The ribbons did not undergo any physical or chemical change, and their end use remained the same. Applying the settled test for manufacture, no new and distinct commercial commodity came into existence. The expression "whether or not" in the tariff entry was treated as covering ribbons on spools or in cartridges as excisable goods, but not as creating a separate act of manufacture. The process was therefore outside the scope of manufacture under section 2(f).

Conclusion: The process did not amount to manufacture and the goods resulting from it were not liable to central excise duty.

Ratio Decidendi: Where duty-paid goods are merely placed into spools, cassettes or cartridges without any change in character, identity or end use, the process does not amount to manufacture unless the statute clearly treats that operation itself as manufacture.

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