Mere cutting of duty-paid paper rolls is not manufacture, so excise duty on adding machine rolls cannot be sustained.

Cutting duty-paid jumbo paper rolls to the required size, without coating, impregnating, corrugation, creping or similar processing, was treated as mere cutting and not manufacture. On those facts, no new excisable product arose, so duty under Tariff Item 17(1) was not sustainable on the resulting adding machine rolls. The legal effect is that simple size reduction of duty-paid paper, by itself, does not bring the product within the excise levy as a manufactured commodity.

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Issues: Whether mere cutting of duty-paid paper rolls to required size amounts to manufacture so as to attract duty under Tariff item 17(1) of the Central Excise Tariff.

Analysis: The goods were made from duty-paid jumbo paper rolls by cutting them to the required size, without any treatment such as coating, impregnating, corrugation, creping or similar processing. On these facts, the process was held to be only cutting and not a manufacturing process giving rise to a new excisable product.

Conclusion: Mere cutting of duty-paid paper does not amount to manufacture, and the levy of duty on the adding machine rolls was not sustainable.

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