Drawing wire from wire rods is not manufacture where prior Tribunal rulings treat the process as non-qualifying.

Drawing wire from wire rods by reducing thickness was treated as non-manufacture, because earlier Tribunal decisions had already held that the process did not bring about a new product and that view had been followed in later authority. The issue was considered settled in favour of the assessee, and no reason was found to depart from those precedents. Accordingly, the process did not amount to manufacture and the Revenue's appeal failed.

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Issues: Whether drawing wire from wire rods by reducing thickness constitutes manufacture.

Analysis: The process of drawing wire from wire rods was held to be non-manufacture in earlier Tribunal decisions, and that view had also been followed in a later decision. The issue was treated as settled in favour of the assessee, and no reason was found to differ from those authorities.

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

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