Scent added to til oil is not manufacture where the oil's essential character and commercial identity remain unchanged.

Adding scent to ordinary til oil did not change its essential character or create a new commercial commodity, so the process was not treated as manufacture. The court applied a common-sense test of transformation and found no positive material showing that the oil had become a different product in trade. On that basis, scented til oil was held not to amount to perfumed hair-oil for manufacture purposes, and the reference was answered in favour of the assessee.

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Issues: Whether mixing scent in ordinary til oil amounts to manufacture of perfumed hair-oil.

Analysis: The addition of scent to ordinary til oil did not, on the record, bring about any change in the essential character of the goods or create a new commercial commodity. The matter was tested on common experience, and in the absence of positive material showing a transformation in the nature of the oil, the process could not be treated as manufacture.

Conclusion: Mixing scent in ordinary til oil does not amount to manufacture of perfumed hair-oil, and the answer to the reference is against the Commissioner and in favour of the assessee.

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