PVC coating of G.I. wire is not manufacture where no new product emerges, so central excise duty does not apply.

PVC coating of G.I. steel wire was held not to amount to manufacture because the process did not bring into existence a new or commercially distinct product. A mere change in tariff heading was treated as insufficient to alter the character of the goods, and the relevant tariff structure did not treat PVC coating as a declared manufacturing process. The analysis also relied on prior authority that insulation or PVC coating of wire, without emergence of a new product, does not create excisability. On that basis, central excise duty was not payable and the impugned order was found unsustainable.

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Issues: Whether PVC coating of G.I. steel wire amounts to manufacture and is therefore liable to central excise duty.

Analysis: The appeal turned on whether the coating process brought into existence a new product or a commercially distinct article. The reasoning accepted that a change in tariff heading does not by itself alter the character of the goods, and that the applicable tariff description did not treat PVC coating as a declared process of manufacture under the relevant tariff structure. The decision also followed prior authorities holding that insulation or PVC coating of wires, without emergence of a new product, does not amount to manufacture.

Conclusion: PVC coating of G.I. wire does not amount to manufacture and no duty is payable; the impugned order was unsustainable.

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