Mere change in tariff classification due to processing not automatically translate to ‘manufacture’

Oil Country Tubular Ltd Vs Commissioner of Central Tax Hyderabad – III (CESTAT Hyderabad)

In the case of Oil Country Tubular Ltd vs Commissioner of Central Tax Hyderabad – III (CESTAT Hyderabad), the issue revolved around whether certain processes undertaken by the appellant on stainless steel pipes amounted to ‘manufacture’ under Central Excise law.

Background and Facts:

1. Appellant’s Activities: Oil Country Tubular Ltd (the appellant) purchased stainless steel pipes primarily used for oil and gas exploration. They performed various processes on these pipes, such as upsetting, heat treatment, inspection, testing, threading, and external coating. These processes aimed to make the pipes suitable for oil drilling purposes. The appellant also manufactured couplings that were affixed to these pipes.

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