Manufacture in excise law extends to laminated kraft paper when processing creates a distinct marketable commodity.

Lamination of duty-paid kraft paper with polyethylene is treated as manufacture because it produces a distinct, marketable article known as laminated kraft paper. Under excise law, manufacture includes a process that brings into existence goods with a separate character and identity, even if the base material was already duty paid. The fact that the finished product may fall within the same tariff entry does not prevent it from being separately identifiable for excise purposes. The resulting laminated kraft paper is therefore liable to excise duty.

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Issues: Whether lamination of duty-paid kraft paper with polyethylene results in manufacture of a new excisable commodity.

Analysis: Lamination of kraft paper with polyethylene brings into existence a different product known in the market as laminated kraft paper. In excise law, manufacture includes the emergence of goods having a distinct and identifiable character and function. The fact that the base material was duty paid does not prevent a subsequent process from amounting to manufacture; at most, any duty-paid credit relief would be governed by the relevant excise rules. Even if the product may fall within the same tariff entry, it remains a separately identifiable commodity for excise purposes.

Conclusion: The process amounts to manufacture and the resulting laminated kraft paper is liable to excise duty.

Ratio Decidendi: A process that transforms duty-paid goods into a distinct and marketable article with separate and identity constitutes manufacture for excise purposes, making the resultant product dutiable.

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