PVC coating on steel wire can amount to manufacture when it creates a distinct insulated conductor for tariff classification.

PVC coating of galvanised steel wire was treated as a manufacturing process because it converted the wire into insulated PVC coated wire with a distinct tariff identity. On that reasoning, the resultant product was classified under the tariff entry for insulated electric conductors, not under the heading for plain steel wire. The Tribunal followed its earlier view that the change in character and use created a new excisable product, so classification under sub-heading 8544.00 was upheld and the assessee's contrary claim under sub-heading 7217.90 failed.

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Issues: Whether PVC coating on steel wire amounts to manufacture and whether the resultant product is classifiable under sub-heading 8544.00 instead of sub-heading 7217.90.

Analysis: The Tribunal followed its earlier decision holding that conversion of G.I. steel wires into PVC coated insulated wires brings about a change amounting to manufacture. On that view, the coated wire is treated as a different excisable product and falls under the tariff entry meant for insulated electric conductors rather than under the heading for steel wire.

Conclusion: The process amounts to manufacture and the product is classifiable under sub-heading 8544.00. The issue is decided in favour of the Revenue and against the assessee.

Ratio Decidendi: Where coating steel wire with PVC results in insulated wire having a different tariff identity, the process amounts to manufacture and the product is classifiable under the tariff entry for insulated electric conductors.

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