Restoration of goods is not manufacture when the process leaves the commodity substantially unchanged and preserves resale deduction.

Recharging dry batteries after removing and later restoring electrolyte did not amount to manufacture because the process did not change the nature or character of the goods. The controlling test is whether post-purchase processing creates a new commodity or merely restores the same commodity to usable condition. On that reasoning, batteries sold after recharging remained the same goods originally purchased, so the sale was treated as resale rather than a fresh manufactured product, and the resale deduction was available.

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Issues: Whether recharged dry batteries sold by the dealers could be treated as resale of the same goods purchased from the manufacturers so as to qualify for deduction under section 8 of the Bombay Sales Tax Act, 1959, or whether the recharging process amounted to manufacture within the meaning of section 2(17).

Analysis: The purchased batteries and the batteries sold after reintroduction of electrolyte and recharging remained substantially the same commodity. The statutory definition of manufacture was not to be read so widely as to cover every minor or ancillary process applied after purchase. The controlling test was whether the process brought about an alteration in the nature or character of the goods. Since the electrolyte had only been removed for transport and the dealers merely restored the batteries to their usable condition without creating a new commodity, the process did not amount to manufacture for purposes of the resale deduction.

Conclusion: The batteries sold by the dealers were resale of the goods purchased by them and not a different commodity; the assessee was entitled to the deduction, and the appeal failed.

Ratio Decidendi: A limited restoration or preparatory process applied to goods after purchase does not constitute manufacture unless it changes the nature or character of the goods; resale in substantially the same commodity remains eligible for deduction.

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