2003 (1) TMI 502

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....elkar, DR, for the Respondent. [Order per : Gowri Shankar, Member (T)]. -  The question for consideration in this appeal is whether the activity that the appellant undertook of fixing of high density polyethylene on the inner surface of pipes and mild steel amounts to manufacture. In the order impugned in the appeal, the Commissioner has held that the process imparts to the steel pipes ....

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....in question, the commodity that emerges is so different than unlined pipe as to say that it is a new product having a distinct character and use. The Commissioner may no doubt be right when he says that the fixing of plastic lining imparts to the pipes the quality of resistance to corrosion, abrasion etc. so that they can be used to transport goods which they otherwise could not have. That however....