Paper coating on cable wire does not amount to manufacture absent a new commercially recognised product.

Coating cable wire received from outside with paper was treated as not amounting to manufacture because the process did not create a new commercially recognised product. The Tribunal followed binding precedent on coating or insulation of wire and held that adding safety, insulation, or only a slight variation in insulation is insufficient to establish manufacture. As the revenue failed to show that the activity brought into existence a distinct excisable article or otherwise satisfied the test of manufacture, the process was held non-excisable and the assessee succeeded.

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Issues: Whether coating cable wire received from outside with paper amounted to manufacture and rendered the product excisable.

Analysis: The Tribunal held that the facts were covered by binding precedent on coating or insulation of wire, where such treatment did not result in a new commercially recognised article. Mere addition of safety to insulation or slight variation in insulation was held insufficient to establish manufacture. The revenue had not shown that the process brought into existence a new product or that the activity was otherwise a process of manufacture.

Conclusion: The process of coating the cable wire with paper did not amount to manufacture, and the assessee succeeded.

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