Manufacture and excisability of tower components found absent where duty-paid steel items were only cut and drilled for erection.

Cutting duty-paid MS angles, rods, plates and channels to customer specification and drilling holes for tower erection was treated as a non-manufacturing activity, so the resulting tower components were held not dutiable. The appeal challenged only the Tribunal's concurrent factual finding on excisability, and no legal error was shown. As no substantial question of law arose from that determination, the appeal failed.

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Issues: Whether any substantial question of law arose from the Tribunal's finding that the fabricated tower components were not dutiable and that no manufacture was involved.

Analysis: The respondent processed duty-paid MS angles, rods, plates and channels by cutting them to customer specification and drilling holes for use in tower erection. The authorities below differed on excisability, but the Tribunal accepted the view that the activity did not amount to manufacture and that the resulting items were not dutiable. The appeal challenged only that concurrent factual determination, and no legal error was shown.

Conclusion: No substantial question of law arose for consideration, and the appeal failed.

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