Manufacture requires emergence of a new and distinct product; wiring harness processing alone was insufficient.

Cutting and processing wiring harness did not amount to manufacture because the process did not bring into existence a new and distinct commodity. The classification of the goods was not disputed, but the departmental case failed to show that the process altered the substance of the product or changed it into a different article. Mere change in the manufacturing process, without evidence of emergence of a new product, was insufficient to satisfy the test of manufacture. The finding in favour of the assessee was upheld and the departmental appeal was rejected.

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Issues: Whether the process undertaken on wiring harness amounted to manufacture resulting in emergence of a new product.

Analysis: The classification of the goods was not in dispute. The dispute turned on whether cutting and processing the wiring harness brought into existence a distinct commodity. The departmental case did not substantiate that the process altered the substance so as to produce a new product. Mere change in the manufacturing process, without evidence of emergence of a new article, was held insufficient to constitute manufacture.

Conclusion: The process did not amount to manufacture and no new product came into existence; the finding in favour of the assessee was upheld.

Final Conclusion: The departmental appeal was rejected and the order holding the process as non-manufacture stood confirmed.

Ratio Decidendi: A process amounts to manufacture only when it results in the emergence of a new and distinct product; a mere change in process or form, without proof of a new commodity, is insufficient.

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