Integrated manufacturing process principle confirms gloves used in hazardous production qualify for sales tax exemption.

Gloves supplied to registered dealers for use by workmen in hazardous manufacturing operations were treated as goods used in the manufacture of goods for sale under the relevant sales tax exemption provision. The Court construed the phrase in line with the integrated process of manufacture, holding that goods used in a process so closely and integrally connected with production that commercial manufacture would be inexpedient without them fall within the statutory expression. The gloves were therefore used in the course of manufacture, and the exemption was admissible.

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Issues: Whether gloves sold to registered dealers for use by their workmen in hot jobs or in handling corrosive substances during manufacturing operations were goods used in the manufacture of goods for sale within section 5(2)(a)(ii) of the Bengal Finance (Sales Tax) Act, 1941.

Analysis: The expression "for use by him in the manufacture of goods for sale" was construed in the light of the corresponding language in section 8(b) of the Central Sales Tax Act, 1956. The governing principle applied was that manufacture covers the entire integrated process of converting raw materials into finished goods, and goods used in a process so closely and integrally connected with ultimate production that manufacture would be commercially inexpedient without it fall within the expression. The gloves were meant for workmen engaged in hazardous manufacturing operations and were therefore used in the course of manufacture.

Conclusion: The gloves were goods used in the manufacture of goods for sale and the exemption was admissible.

Final Conclusion: The appeal was dismissed and the High Court's view in favour of the assessee was upheld.

Ratio Decidendi: Goods used in a process integrally connected with manufacturing, without which commercial production would be inexpedient, are treated as goods used in the manufacture of goods for sale for the purpose of sales tax exemption.

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