In situ polyurethane foam formation was not manufacture, so the resulting product was not subject to excise duty.

The in situ injection of polyols and isocyanates into article cavities to form polyurethane foam was treated as not amounting to manufacture under Section 2(f) of the Central Excises and Salt Act, 1944. Relying on earlier Tribunal decisions, the Tribunal held that the process did not create a new manufactured product for excise purposes. As a result, the polyurethane foam formed in situ was not liable to excise duty.

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Issues: Whether the in situ process of injecting Polyols and Isocyanates into the cavity of articles like water jugs to form polyurethane foam amounted to manufacture under Section 2(f) of the Central Excises and Salt Act, 1944, and whether the resultant product was liable to excise duty.

Analysis: The process had already been held in earlier Tribunal decisions not to amount to manufacture within the meaning of Section 2(f). Following those decisions, the Tribunal found no reason to take a different view in the present matter. The formation of polyurethane foam in situ did not constitute a manufacturing process attracting excise duty.

Conclusion: The in situ process did not amount to manufacture and the resultant product was not dutiable.

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