Manufacture test for tower components failed where shaping operations did not create excisable goods.

Cutting, punching, drilling, straightening, notching and bending of duty-paid angles, channels and plates used for transmission towers and sub-station structures did not amount to manufacture, because the operations merely prepared components for site assembly and did not bring into existence a new product. Following earlier Tribunal rulings on similar processes, the resultant components were therefore not excisable goods under Tariff Item 68.

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Issues: Whether cutting to size, punching of holes, drilling, straightening, notching and bending of angles, channels and plates used for transmission towers and sub-station structures amounted to manufacture, and whether the resulting products were excisable under Tariff Item 68 of the Central Excise Tariff.

Analysis: The process undertaken consisted of cutting, punching and related shaping operations on angles, channels and plates to prepare components for assembly at site. The issue had already been covered by earlier Tribunal decisions holding that similar processes on duty-paid inputs did not bring into existence a manufactured product. Following those decisions, the process in question was treated as falling short of manufacture, and the resultant components were not regarded as excisable goods.

Conclusion: The process did not amount to manufacture and the products resulting from it were not excisable.

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