Metallising printed polyester film was not manufacture where the product's essential character remained unchanged and no new excisable goods emerged.

Metallising duty-paid printed polyester film received on job-work basis did not amount to manufacture for excise purposes because the film already fell within the relevant tariff description and the process did not alter its essential character or use. Section 2(f) of the Central Excises and Salt Act, 1944 was not to treat metallising as manufacture in the absence of a specific statutory or tariff note deeming it so. As no fundamentally new excisable product emerged, no excise duty was leviable on the metallising activity.

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Issues: Whether metallising printed polyester film received from outside on job-work basis amounted to manufacture attracting excise duty.

Analysis: The printed polyester film was already a duty-covered article under the relevant tariff description, and metallising did not change its essential character or use. Section 2(f) of the Central Excises and Salt Act, 1944 did not treat metallising as a process specified in the section or chapter notes as amounting to manufacture. The tariff entry covered films whether or not metallised, and the process in the assessee's premises did not bring into existence a fundamentally new excisable product where duty-paid printed film was merely metallised after being brought from outside.

Conclusion: Metallising the printed polyester film did not amount to manufacture and no excise duty was leviable on that activity against the assessee.

Ratio Decidendi: Where duty-paid goods already fall within the same tariff description and a later process does not alter their essential character or use, the later process is not manufacture unless it is specifically treated as such by the statute or tariff notes.

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