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    <description>Fabrication and erection of steel structurals at site was held not to amount to manufacture because the processes did not produce a new, distinct and marketable commodity with separate identity, use and character; the structures were treated as part of an immovable structure and not excisable goods. Duty also could not be fastened on the appellants because the fabrication was admittedly carried out by independent sub-contractors, and liability, if any, lay on the actual manufacturer rather than on a coordinating contractor. On that reasoning, the demand and penalty were unsustainable.</description>
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