Manufacture for excise duty is not made out when wire drawing produces no commercially distinct commodity.

Drawing wire rods into thinner wire did not amount to manufacture for excise duty where both the input and the finished product remained within the tariff description of "wire". The explanation to Tariff Item 26AA(i-a) treated wire as a cold-drawn product within the specified cross-sectional limit, and the process of reducing gauge did not create a commercially distinct commodity. On that reasoning, no new excisable product emerged merely because the wire became thinner, so additional duty was not attracted and the demand could not be sustained.

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Issues: Whether drawing wire of a lesser gauge from wire rods of a higher gauge amounted to manufacture attracting excise duty under Tariff Item 26AA(i-a).

Analysis: The product obtained by drawing wire rods into thinner wires remained within the tariff description of "wire". The explanation to the tariff entry treated wire as cold drawn products with no cross-sectional dimension exceeding 13 mm. Since the raw material and the resultant product both fell within that description, and the resultant product did not emerge as a commercially different commodity, the process did not create a new excisable product merely because the gauge was reduced.

Conclusion: The process did not amount to manufacture attracting further duty, and the demand could not be sustained.

Ratio Decidendi: Where the resultant product continues to fall within the same tariff description as the raw material and no new commercially distinct excisable commodity emerges, mere reduction in gauge does not constitute manufacture for excise duty.

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