Commercially necessary goods for manufacturing qualify for inclusion even when they are not ingredients of the finished product.

Goods directly and commercially necessary for carrying on manufacture may be included in the registration certificate even if they do not form part of the finished product. Lamps used to light the plant area were treated as essential to keep manufacturing operations running, and the remaining disputed items, including screens, oil seals, wagon components and packing material, were accepted on the basis of the company's affidavit in the absence of any counter-affidavit. The item described as No. 2 was rejected for vagueness, but the other specified items were treated as falling within the wider construction given to goods used in manufacture.

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Issues: Whether lamps used for lighting the manufacturing plants and the other disputed spare parts and consumables were goods directly required for use in the manufacture and processing of iron and steel so as to be included in the registration certificate under section 6A of the Bihar Sales Tax Act, 1959.

Analysis: The relevant test was whether the goods were directly required for the manufacturing and processing activity and whether, having regard to the normal conditions of the industry, their use was commercially necessary for carrying on the manufacturing process. Lamps used for lighting the plant area were found to be essential to keep the manufacturing operations going and were not comparable to office equipment or other items unconnected with production. The affidavit filed on behalf of the company was accepted for the remaining disputed items, and in the absence of any counter-affidavit the goods described as screens, oil seals, wagon components, and packing material were treated as falling within the wider construction previously applied to the expression governing concessional inclusion of goods used in manufacture.

Conclusion: Item No. 2 was rightly disallowed for vagueness, but items Nos. 1 and 3 to 10 were entitled to inclusion in the registration certificate; the rejection was therefore interfered with only to that extent.

Ratio Decidendi: Goods that are directly and commercially necessary for carrying on the manufacturing process, though not themselves ingredients of the finished product, qualify for inclusion where the statutory phrase receives a liberal construction.

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