Mere decoration of glazed tiles does not amount to manufacture where the original commercial identity remains unchanged.

Processing duty-paid plain glazed tiles into decorated ceramic glazed wall tiles did not amount to manufacture because the operation did not create a commercially different commodity or destroy the identity of the original tiles. The added decoration merely altered appearance, while the basic character and use of the goods remained unchanged. Mere printing or decoration, without change in commercial identity, is insufficient to constitute manufacture. Later tariff deeming provisions were held inapplicable to the period in issue, so the duty demand, confiscation and penalties could not be sustained.

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Issues: Whether processing duty-paid plain glazed tiles into decorated ceramic glazed wall tiles amounted to manufacture of a new and distinct commercially known product.

Analysis: The decisive test was whether the process brought into existence a different commercial commodity or whether the original commodity ceased to retain its identity. Applying that test, the Tribunal held that the plain glazed tiles remained tiles even after decoration, and the added process only altered their appearance. The Tribunal followed the principle that mere printing or decoration, without a change in the basic character or commercial identity of the goods, does not amount to manufacture. The later deeming provisions in the tariff were not applicable to the period in dispute.

Conclusion: The process did not amount to manufacture, and the duty demand, confiscation and penalties could not stand.

Ratio Decidendi: A process amounts to manufacture only if it results in a commercially different commodity or destroys the identity of the original commodity; mere decoration or printing that leaves the basic character and use unchanged does not create a new excisable product.

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