TMI Blog2003 (1) TMI 502X X X X Extracts X X X X X X X X Extracts X X X X ..... . 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 qualities of resistance to corrosion, abrasion, chemical action and stress and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t 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 is not sufficient to conclude that character and use of the pipes has changed to such an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r v. Union of India - 1988 (36) E.L.T. 28, that providing fixing rubber lining to tanks and vessels of metal does not amount to manufacture and the Circular 139/94/87-CX.14, dated June, 1988 of the Board advising the officials under it that the process of coating steel pipes with cement mortar on the outside and epoxy or bitumen bonding on the inside does not amount to manufacture. The process wit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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