Commissioner Of Central Excise, Jaipur vs M/S. Hindustan Zinc Ltd

The Supreme Court held that the process of manufacturing cathodes and anodes for electrolysis results in the creation of a new product with distinct name, character, and use, thus constituting 'manufacture' under the Central Excise Act. The Court found that the Tribunal erred in concluding that no new product emerged, as the electrodes are marketable and accepted as such by the industry. The Court upheld the Commissioner of Customs and Central Excise's order for duty payment, reversing the Tribunal's decision.