Marble cutting is not manufacture where sawing blocks into slabs and tiles leaves the commodity's identity unchanged.

Sawing marble blocks into slabs and marble tiles was treated as a process that does not create a new and distinct commodity with an independent identity. The settled test of manufacture was applied: a process amounts to manufacture only where it results in transformation into a different product. On the facts, cutting marble merely changed the form of the same material, so the essential identity of the commodity remained unchanged. Prior judicial precedent on similar stone-cutting processes was also relied upon. The process was therefore not manufacture, and the Revenue's appeal failed.

---

---

Issues: Whether sawing of marble blocks into slabs and marble tiles amounts to manufacture.

Analysis: The dispute arose from the cutting of marble blocks into slabs and tiles during the relevant period. The reasoning accepted the settled principle that a process amounts to manufacture only when it results in a new and distinct product with a separate identity. On the facts, the process of sawing or cutting marble did not bring into existence a different commodity; the essential identity of the material remained the same. The appeal was also examined in the light of prior judicial precedent on similar stone-cutting processes.

Conclusion: The process did not amount to manufacture, and the Revenue's appeal failed.

---