Trailer modifications with cabins and tanks were held not to create a new excisable product or change classification.

Adding toilet cabins, sewage tanks and fluid tanks to duty-paid trailers was treated as body-building activity and not as manufacture of a new excisable product, because the trailers did not acquire a distinct name, character or use. Chapter Note 3 to Chapter 87 was held inapplicable to trailers under Heading 87.16, so the additions did not alter the trailers' classification or attract fresh duty under Heading 8716.00. Classification under Heading 94.06 as a prefabricated structure was left open for examination by the proper authority.

---

---

Issues: Whether fixing toilet cabins, sewage tanks and fluid tanks in duty-paid trailers amounts to manufacture of trailers chargeable again to duty under Heading 8716.00, and whether such activity alters the classification of the trailers.

Analysis: The trailers had already suffered duty as trailers. The addition of toilet cabins, sewage tanks and fluid tanks was treated as body-building activity and did not bring into existence a new product with a distinct name, character and use. The applicability of Chapter Note 3 to Chapter 87 was considered, but it was held that the note did not apply to trailers falling under Heading 87.16. The possibility of classification under Heading 94.06 as a prefabricated structure was left open for examination by the proper authority.

Conclusion: The impugned additions did not amount to manufacture of a fresh excisable product under Heading 8716.00, and the Revenue's appeal was rejected.

---