Manufacture requires a new and distinct commodity; pipe lining that only improves durability is not enough.

Fixing high density polyethylene lining on the inner surface of pipes did not amount to manufacture because the process did not bring into existence a new and distinct commodity with a different name, character and use. Although the lining improved resistance to corrosion, abrasion and chemical action, the essential function of the goods remained transportation of liquids or gases, and their basic identity as pipes was unchanged. Mere improvement in utility or suitability is insufficient to constitute manufacture.

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Issues: Whether fixing high density polyethylene lining on the inner surface of pipes and mild steel amounts to manufacture.

Analysis: For a process to amount to manufacture, it must result in emergence of a new commodity having a distinct name, character and use. The lining imparted resistance to corrosion, abrasion and chemical action, but the essential function of the pipes remained transportation of liquids or gases. The basic character of the goods was not altered, and the processed goods continued to be pipes.

Conclusion: The process did not amount to manufacture.

Ratio Decidendi: A process amounts to manufacture only when it brings into existence a new and distinct commodity with a different name, character and use; mere improvement in utility or suitability does not suffice.

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