Change in physical form alone is not manufacture where aluminium retains its essential identity and no new commercial product emerges.

Melting aluminium ingots into round ingots or billets for extrusion did not amount to manufacture because the process only changed the physical form of unwrought aluminium without altering its essential chemical composition or creating a new commercially distinct commodity. Ingots and billets were treated as different forms of the same unwrought aluminium, so no dutiable new product arose and no duty liability attached.

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Issues: Whether melting aluminium ingots into round ingots or billets for extrusion amounts to manufacture and creates a dutiable new commodity.

Analysis: The process undertaken only altered the shape of unwrought aluminium to make it suitable for extrusion. The materials retained the same essential chemical composition, and the cited technical and tariff references showed that ingots and billets are different forms of the same unwrought aluminium. Mere change in physical form or shape, without emergence of a new commercially distinct commodity, does not amount to manufacture.

Conclusion: The process did not amount to manufacture and no duty liability arose.

Ratio Decidendi: Mere conversion of a commodity into another physical form, without bringing into existence a new and distinct commercial product, does not constitute manufacture.

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