Manufacture requires a new product with distinct identity; treating nickel cylinders for printing was not enough.

Preparation of nickel perforated cylinders for fabric printing was held not to amount to manufacture because the process of heating, pounding, degreasing, chemical treatment, exposure and curing did not create a new product with a distinct identity. The cited precedent on affixing or changing designs on such cylinders was treated as fully applicable, as the cylinders remained the same article after treatment. Mere preparation of an existing item for use in a printing machine was therefore insufficient to satisfy the test of manufacture, and the appeal succeeded.

---

---

Issues: Whether the process of making nickel perforated cylinders ready for use in printing of fabrics amounted to manufacture.

Analysis: The process involved heating, pounding, degreasing, treatment with photosensitive chemicals, exposure of design to light, and developing and curing before fitting the cylinders to rotary printing machines. The cited precedent held that affixing or changing the design on nickel perforated cylinders did not bring into existence a new product, and that the cylinders remained the same. The present facts were found to be fully covered by that decision.

Conclusion: The activity did not amount to manufacture and the appeal succeeded.

Ratio Decidendi: A process does not amount to manufacture unless it results in a new product with a distinct identity; mere preparation or treatment of an existing article for use does not satisfy that test.

---