Manufacture requires a new marketable commodity; simple fabrication of steel inputs was not excisable goods under Chapter Heading 7308.90.

Mere cutting, punching, drilling, bending or galvanizing of duty-paid MS angles, channels, flats and rods does not amount to manufacture unless a new and marketable commodity emerges with a distinct name, character or use. The fabricated transmission-line materials remained unmarketable in the form produced and were covered by prior Tribunal decisions on similar operations. As no excisable goods came into existence, the items were not classifiable as parts of structures under Chapter Heading 7308.90, and the Revenue's appeals failed.

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Issues: Whether the processes of cutting, punching, drilling, bending and galvanizing of MS angles, channels, flats and rods used for transmission line materials amount to manufacture and result in excisable goods classifiable under Chapter Heading 7308.90 as parts of structures.

Analysis: The processes undertaken did not bring into existence a new commodity with a distinct name, character or use. The materials remained unmarketable in the form in which they emerged, and the issue was already covered by earlier Tribunal decisions holding that similar cutting, punching and bending operations do not amount to manufacture. The Tribunal also found that the cited precedent and the tariff scheme supported the view that such fabricated items were not liable to classification as goods under Chapter Heading 7308.90.

Conclusion: The processes did not amount to manufacture, the items were not goods, and they were not classifiable under Chapter Heading 7308.90; the Revenue appeals failed.

Ratio Decidendi: Mere cutting, punching, drilling, bending or galvanizing of duty-paid steel inputs, without emergence of a new and marketable commodity, does not amount to manufacture for excise purposes.

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