Project-specific curtain wall installation is not manufacture when no distinct marketable product emerges for excise purposes.

Fabrication and on-site installation of curtain wall or structural glazing using aluminium frames and pre-cut glass for a specific project does not amount to manufacture where the assembled components do not emerge as a distinct, commercially marketable product. The process was treated as an indivisible works contract for installation as part of the civil structure, not as a supply of independently marketable glazed panels. On that basis, the activity fell outside manufacture for central excise purposes and was not exigible to central excise duty.

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Issues: Whether the activity of fabricating and installing curtain wall or structural glazing by assembling aluminium frames and pre-cut glass at the site resulted in manufacture of a new marketable product exigible to central excise duty.

Analysis: The process involved design-based fabrication of aluminium frames, fixing of pre-cut glass with sealant, and simultaneous erection of glazed panels as part of the civil structure. The components were made to specific dimensions for the particular project and were not shown to be commercially marketable as separate goods before installation. The Revenue's reliance on the tariff entry and on the cited precedent was held inapposite because the facts showed an indivisible works contract for installation of a curtain wall and not a supply of independently marketable glazed panels.

Conclusion: The activity did not amount to manufacture under Section 2(f) of the Central Excise Act, 1944, and no central excise duty was leviable.

Ratio Decidendi: Fabrication and on-site installation of project-specific components that do not emerge as a distinct commercially marketable product do not constitute manufacture for central excise purposes.

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