Re-conditioning of roller shafts is not manufacture where no new commercial product emerges.

Re-shelling and re-grooving of worn roller shafts was held to be re-conditioning work that restored usability rather than manufacture. The decisive test applied was whether a new and different article with a distinct name, character or use emerged; because the shafts remained roller shafts before and after treatment, the process merely prolonged their life and did not create a new commercial product. Accordingly, the activity did not fall within the statutory concept of manufacture under Section 2(f), no duty arose under Tariff Item 68, and the show cause notice was discharged.

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Issues: Whether re-shelling and re-grooving of worn roller shafts amounts to manufacture so as to attract duty under Tariff Item 68.

Analysis: The process undertaken on the roller shafts was for re-conditioning and restoring usability of the existing goods. The decisive test applied was whether a new and different article emerged with a distinct name, character or use. As the roller shafts remained roller shafts before and after treatment, and the work merely prolonged their life without creating a new commercial product, the process did not satisfy the statutory concept of manufacture under Section 2(f).

Conclusion: Re-shelling of roller shafts does not amount to manufacture and no duty liability arises under Tariff Item 68. The show cause notice was rightly discharged and the appeal failed.

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