Expanded meaning of manufacture includes preparing goods for sale, so cutting iron and steel scrap qualified for exemption.

Under the Madhya Pradesh General Sales Tax Act, 1959, "manufacture" was construed in its expanded statutory sense, covering producing, collecting, extracting, preparing, or making goods. Because the definition was not limited to the creation of a new article, authorities under narrower enactments were not decisive. Mechanically cutting bulky iron and steel scrap into smaller pieces suitable for rolling mills and foundries was held to be a process that prepared and made the goods saleable, and therefore fell within the statutory meaning of manufacture. The appellants were entitled to the exemption, and the High Court's view was reversed.

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Issues: Whether cutting and sizing iron and steel scrap into smaller usable pieces amounted to "manufacture" within section 2(j) of the Madhya Pradesh General Sales Tax Act, 1959 so as to entitle the appellants to the exemption.

Analysis: The statutory definition of "manufacture" was framed in expansive terms, including producing, collecting, extracting, preparing, or making goods. The text of the definition itself showed that the legislature did not intend the term to be confined to the production of a new article, because it expressly extended to activities such as collecting goods and lopping or cutting trees, which do not create a new product. In that setting, decisions under other enactments with narrower or different definitions were not determinative. The appellants' activity of mechanically cutting bulky scrap into pieces suitable for rolling mills and foundries was a process that prepared and made the goods saleable and therefore fell within the wide statutory meaning.

Conclusion: The activity constituted "manufacture" under section 2(j), and the appellants were entitled to the exemption.

Final Conclusion: The High Court's view was reversed, and the appellants' eligibility to the exemption was restored.

Ratio Decidendi: Where a statute defines "manufacture" in expansive terms that include preparing, collecting, or making goods, the term is not confined to the emergence of a new article, and a process that makes goods saleable may amount to manufacture.

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