Temporary engine substitution for testing did not create a new excisable commodity, so no additional duty arose.

Temporarily removing the imported engines from forklift trucks and fitting locally manufactured engines for testing and exhibition did not create a new commercially distinct product. The goods remained the same imported forklift trucks throughout, and the original parts were later restored. Because no process of manufacture resulting in a new excisable commodity was established, the activity did not amount to manufacture and no additional duty was payable on the forklift trucks.

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Issues: Whether temporarily removing the imported engines from the imported forklift trucks and fitting locally manufactured engines for testing and exhibition amounted to manufacture of a new excisable commodity attracting duty.

Analysis: The facts were admitted and the sequence of events showed that the forklift trucks remained the same imported goods throughout. The temporary substitution of engines and transmissions for testing purposes, followed by restoration of the original imported parts, did not bring into existence a new commercially distinct product. No process of manufacture resulting in a new commodity was established.

Conclusion: The activity did not amount to manufacture and no additional duty was payable on the forklift trucks.

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