Manufacture requires emergence of a commercially different product; mere cutting and punching of bought-out steel goods is not manufacture.

Cutting, bending, punching and making holes on bought-out iron and steel articles was held not to amount to manufacture because no commercially different product emerged from the processing. The department failed to dislodge the factual finding that the activity remained mere processing of purchased goods, and the Board's clarification that cutting and punching of iron and steel products does not amount to manufacture was treated as binding on the department. The duty demand could not be sustained.

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Issues: Whether cutting, bending, punching and making holes on bought-out iron and steel articles amounts to manufacture.

Analysis: The activity was held not to amount to manufacture because the department had not established that the processed goods resulted in emergence of a commercially different article. The adjudicating authority had also relied on the Board's clarification that cutting and punching of iron and steel products does not amount to manufacture, and it was noted that such circulars are binding on the department. On the facts, there was no material to dislodge the finding that the activity remained mere processing of bought-out goods.

Conclusion: The activity did not amount to manufacture and the duty demand could not be sustained.

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