Broad meaning of "processed" under sales tax law covers mechanical conversion for sale, and camphor remained a notified commodity.

The expression "processed" under section 2(b) of the West Bengal Sales Tax Act, 1954 is to be read in its ordinary breadth, so a person who mechanically converts camphor granules into camphor cubes for sale under his own brand can fall within the definition of dealer even if the commodity retains its essential character. Camphor in the form dealt with was treated as a notified commodity because camphor was regarded as a drug and drugs were within the relevant notification scheme. On that basis, liability under the Act was attracted and the sales tax assessment was sustained.

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Issues: (i) Whether a person who converts camphor granules into camphor cubes by a mechanical process and sells them under his own brand name is a dealer within the meaning of section 2(b) of the West Bengal Sales Tax Act, 1954; (ii) whether camphor, in the form dealt with by the appellant, is a notified commodity so as to attract liability under the Act of 1954.

Issue (i): Whether a person who converts camphor granules into camphor cubes by a mechanical process and sells them under his own brand name is a dealer within the meaning of section 2(b) of the West Bengal Sales Tax Act, 1954.

Analysis: The definition of dealer in section 2(b) extended to a person who sells notified commodities manufactured, made or processed by him in West Bengal. The conversion of camphor granules into cubes involved a continuous and regular mechanical operation carried out in West Bengal for sale in the local market. The term "process" was held to bear its ordinary and general meaning and not to be confined to processing that results in a new commodity. The fact that camphor retained its essential character did not exclude the activity from being processing within the statutory definition.

Conclusion: The appellant was a dealer within section 2(b) of the West Bengal Sales Tax Act, 1954.

Issue (ii): Whether camphor, in the form dealt with by the appellant, is a notified commodity so as to attract liability under the Act of 1954.

Analysis: Camphor had been treated as a drug, and drug was a notified commodity under the relevant notification scheme under the Act of 1954. The appellant could not successfully deny that position after having earlier relied upon it to avoid assessment under the earlier sales tax enactment. On the materials, camphor was treated as falling within the category of notified commodity.

Conclusion: Camphor was treated as a notified commodity, and the appellant's liability under the Act of 1954 was attracted.

Final Conclusion: The challenge to the sales tax assessment failed in full, and the levy under the West Bengal Sales Tax Act, 1954 was sustained.

Ratio Decidendi: A statutory expression like "processed" must be given its ordinary breadth, and a person who mechanically converts a commodity into a marketable form for sale can be treated as processing it even if its intrinsic character remains the same.

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