Mere cutting of marble blocks into slabs is not manufacture where no new commercial product emerges.

Cutting marble blocks into marble slabs does not amount to manufacture under the Central Excise regime because manufacture requires a new and distinct article with a different name, character or use. Mere conversion of marble blocks into slabs, without creation of a commercially different product, leaves the original identity of the goods unchanged. Applying the settled principle from earlier precedent on stone processing, the Court held that cutting and polishing alone is insufficient to constitute manufacture. The appeal succeeded and the Tribunal's order was set aside.

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Issues: Whether cutting marble blocks into marble slabs amounts to manufacture under the Central Excise regime.

Analysis: Manufacture requires the emergence of a new and distinct article having a different name, character or use. Where the process only converts marble blocks into slabs without bringing into existence a commercially different product, the original identity of the goods remains unchanged. On the controlling principle already affirmed in earlier precedent, cutting and polishing stone into slabs does not amount to manufacture when no new product comes into existence.

Conclusion: The activity of cutting marble blocks into marble slabs does not amount to manufacture.

Final Conclusion: The appeal succeeds and the Tribunal's order is set aside.

Ratio Decidendi: A process amounts to manufacture only if it brings into existence a new and distinct commercial product with a different name, character or use; mere cutting of marble blocks into slabs, without such transformation, is not manufacture.

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