Protective gear used in manufacturing can qualify as goods used in manufacture when essential to the production process.

Protective industrial gloves supplied to workmen for handling hot or corrosive materials were held to fall within goods used "in the manufacture of goods" under section 5(2)(a)(ii) of the Bengal Finance (Sales Tax) Act, 1941. The HC treated the phrase as extending beyond raw materials or components to goods essential to a commercially workable manufacturing process. Because the gloves enabled workers to use shovels and rods safely in the course of production, they were sufficiently connected with manufacture and therefore qualified as goods used in manufacture.

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Issues: Whether industrial gloves supplied to workmen for handling hot or corrosive materials in the course of manufacturing process were goods used "in the manufacture of goods" within the meaning of section 5(2)(a)(ii) of the Bengal Finance (Sales Tax) Act, 1941.

Analysis: The expression "in the manufacture of goods" was treated as covering not merely raw materials or components of the finished product, but also goods required in the manufacturing process where the process would become commercially inexpedient without them. Applying that approach, the Court held that protective gloves used by workmen to operate shovels and rods in hot or corrosive conditions were essential for carrying on the manufacturing process. Such apparel enabled the manufacture to be carried on and was therefore sufficiently connected with the process of manufacture.

Conclusion: The industrial gloves were used in the manufacture of goods, and the question was answered in the affirmative in favour of the assessee.

Ratio Decidendi: Goods that are required in an integral and commercially necessary process of manufacture, including protective items enabling workmen to carry on the process, fall within the expression "used in the manufacture of goods".

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