Manufacture requires a new product with distinct name, character or use; mere bending, welding and sand-blasting did not qualify.

Bending, welding and sand-blasting of perforated steel sheets for use in rubber rolls did not amount to manufacture because the processed sheets remained hollow profiles with only a rounded shape and sand-blasting was merely a cleaning process. As no new product with a distinct name, character or use emerged, the activity fell outside manufacture under the Central Excise Tariff. No duty demand arose, and the penalty was unsustainable.

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Issues: Whether the bending, welding and sand-blasting of perforated steel sheets for use in rubber rolls amounted to manufacture so as to attract duty under Heading 73.06 of the Central Excise Tariff.

Analysis: The processed sheets were found to remain hollow profiles even after bending and welding, only acquiring a rounded shape. Sand-blasting was held to be merely a cleaning process. As no new product with a distinct name, character or use emerged, the activity did not amount to manufacture.

Conclusion: The process did not constitute manufacture and no duty demand arose; the penalty was also unsustainable.

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