Assembly of duty-paid components into structural glazing can amount to manufacture when a distinct commercial product emerges.

Assembly of duty-paid aluminium frames, glass sheets and bought-out materials at the buyer's site into a structural glazing system resulted in a distinct commercially identifiable product with a separate name, character and use. The later fixing of the system to a building did not make it immovable property or remove it from excise treatment. The process of combining the components for the buyer's purpose amounted to manufacture under Central Excise law, so the product was treated as manufactured and excisable.

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Issues: Whether aluminium curtain wall structural glazing system, assembled at the buyer's site from duty-paid aluminium frames, glass sheets and bought-out materials, was a manufactured and excisable product.

Analysis: The assembled glazing system emerged as a distinct commodity different from the input materials. It had a separate name, character and commercial identity, and the fact that it was later fixed to a building did not make it immovable property. The process of assembling the components into a product serving the buyer's purpose amounted to manufacture.

Conclusion: The product was held to be manufactured and excisable, and the Revenue succeeded on merits.

Ratio Decidendi: Assembly of duty-paid components and bought-out materials into a distinct commercially identifiable product amounts to manufacture under the Central Excise law, even if the product is later incorporated into a building structure.

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