Slitting jumbo rolls of thermal paper is not manufacture when no new and distinct product emerges.

Slitting jumbo rolls of thermal paper into smaller rolls does not amount to manufacture where the process does not create a new and distinct article with a separate identity. The Tribunal held that the character and end use of the goods remain unchanged after slitting or cutting, so mere size reduction is insufficient to constitute manufacture. The Revenue's appeal was rejected and the assessee's position was upheld.

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Issues: Whether slitting jumbo rolls of thermal paper into smaller rolls amounts to manufacture.

Analysis: The Tribunal followed earlier decisions holding that slitting or cutting jumbo rolls into smaller rolls does not bring into existence a new and distinct article. The character and end use of the goods remain unchanged, and the process does not result in manufacture merely because the rolls are reduced to smaller sizes.

Conclusion: Slitting jumbo rolls of thermal paper into smaller rolls does not amount to manufacture.

Final Conclusion: The appeal filed by the Revenue was rejected and the assessee's position was upheld.

Ratio Decidendi: A process that only slits or cuts jumbo rolls into smaller rolls, without bringing into existence a new product with a distinct identity, does not constitute manufacture.

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