Manufacture test for steel pipes: welding and bolting into poles did not change their essential character.

Converting steel pipes of different dimensions into electric poles by welding and fixing nuts and bolts was treated as a process that did not alter the essential character of the goods. The material remained pipes, albeit of greater length and capable of the same use, and the Department produced no substantial evidence to show a change in identity. Applying the principle that joining pipes or tubes in this manner does not make them cease to be iron and steel pipes or tubes under Item 26AA(ii), the process was held not to amount to manufacture, and the Department's appeal failed.

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Issues: Whether converting steel pipes of different dimensions into electric poles by welding and fixing nuts and bolts amounts to manufacture.

Analysis: The activity was found to leave the product as a pipe, merely of greater length, capable of the same use as other pipes. In the absence of substantial evidence from the Department, the reasoning accepted that the process did not change the essential character of the goods. The conclusion was supported by the principle that putting pipes or tubes together by such processes does not make the resultant goods cease to be iron and steel pipes or tubes under Item 26AA(ii) of the tariff.

Conclusion: The process did not amount to manufacture and the Department's appeal failed.

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