Repair of sugar mill rollers is not manufacture where the process only restores serviceability and creates no new commodity.

Regrooving sugar mill rollers and grooving re-shelled rollers did not amount to manufacture under excise law because the worn-out rollers retained their commercial identity and the work only restored them to a serviceable condition. Reshelling, machining and grooving were treated as repair or reconditioning, not the creation of a new or distinct commercial commodity. No excise duty was leviable on the activity.

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Issues: Whether regrooving of sugar mill rollers and grooving of re-shelled mill rollers amounts to manufacture.

Analysis: The rollers sent out for reshelling were old, worn out rollers which retained their commercial identity. The process of reshelling, machining and grooving merely restored the rollers to a serviceable condition. No new or distinct commercial commodity emerged, and the work amounted only to repair or reconditioning rather than manufacture within the meaning of excise law.

Conclusion: The process did not amount to manufacture and no excise duty was leviable on the activity.

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