Manufacture by processing betel nut into supari supports classification under the tariff entry for the distinct commodity.

Cutting, crushing betel nuts and adding ingredients to produce supari created a new and commercially distinct commodity, so the process constituted manufacture. Chapter Note 4 of Chapter 21, which specifically covers betel-nut powder known as supari, could not be disregarded, and the product was therefore classifiable under Chapter 21 rather than as mere betel nut under Chapter 8. The Tribunal applied the principle that commercially distinct emergence from processing is sufficient to establish manufacture and accepted the Revenue's classification case.

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Issues: Whether the process of cutting/crushing betel nuts into pieces or powder and adding other ingredients to produce supari amounted to manufacture and, consequently, whether the product was classifiable under Chapter 21 rather than Chapter 8.

Analysis: The Tribunal held that the end product was different from the raw material and that a new and distinct commodity, namely supari powder, emerged. It rejected the view that mere retention of the basic character of betel nut negated manufacture. Chapter Note 4 of Chapter 21, which specifically refers to betel-nut powder known as supari, could not be ignored. The Tribunal also relied on the principle that where processing results in a commercially distinct product, manufacture is established, and noted that the cited precedents supported the Revenue's case.

Conclusion: The process amounted to manufacture and the goods were not entitled to classification as mere betel nut under Chapter 8; the Revenue's appeal succeeded.

Ratio Decidendi: When processing betel nut with cutting, crushing and addition of ingredients yields a commercially distinct product described in the tariff, the process constitutes manufacture and the product is classifiable according to the tariff entry specifically covering that distinct commodity.

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