Manual blending of tea is not processing or alteration when the goods retain their nature and character.

Manual blending of different tea varieties purchased from registered dealers was not "processing" under the Bombay Sales Tax Act, because the tea was only mixed in fixed proportions and not subjected to any mechanical or chemical treatment. The court also held that the wider phrase "altered in any manner" required a change in the nature or character of the goods, which mere mixing did not produce, even if it obscured the identity of the components. The assessees were therefore entitled to deduct the purchase value of the tea from their turnover.

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Issues: Whether the mixing and blending of different varieties of tea purchased from registered dealers amounted to "processing" or "altering" the goods within the proviso to section 8(a) of the Bombay Sales Tax Act, 1953, so as to disentitle the assessees to deduction of the purchase value from their turnover.

Analysis: The expression "process" was not defined in the Act, and the relevant inquiry was whether the purchased tea had been subjected to any process, manufacture, development, or preparation after purchase. The blending here was only a manual mixing of tea brands in fixed proportions to produce a marketable tea mixture; the commodity was not subjected to mechanical or chemical treatment and remained in the same condition. Although some skill was involved in preparing the blend, that did not amount to processing. The proviso also used the wider expression "altered in any manner", but the alteration contemplated by the legislature was an alteration in the nature or character of the goods. Mere mixing that obscured the individuality of the components did not constitute such alteration.

Conclusion: The mixing and blending of tea did not amount to processing or alteration within the meaning of section 8(a) of the Bombay Sales Tax Act, 1953, and the assessees were entitled to deduct the value of the purchased tea from their turnover.

Ratio Decidendi: Manual blending of purchased goods, without mechanical or chemical treatment and without change in their nature or character, is not "processing" or "alteration" within a statutory deduction proviso framed in those terms.

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