Manufacture and purchase tax hinge on a commercially distinct commodity; processed pine-apple slices did not attract purchase tax.

Purchase tax under section 5A(1)(a) applied only where purchased goods were consumed in manufacture of other goods for sale, and the decisive test was whether processing produced a commercially distinct commodity. Washing, trimming, slicing, preserving, sealing and sterilising pine-apple did not by itself create a different commercial article because the processed product retained its identity as pine-apple. Pine-apple slices were therefore not "other goods" manufactured from the purchased fruit, and purchase tax was not attracted.

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Issues: Whether pine-apple slices prepared by washing, trimming, slicing, preserving, sealing and sterilising the fruit amounted to consumption of the purchased goods in the manufacture of other goods so as to attract purchase tax under section 5A(1)(a) of the General Sales Tax Act, 1963.

Analysis: Liability under section 5A(1)(a) arises only if the purchased goods are consumed in the process of manufacture and the result is other goods for sale. The controlling inquiry is whether the processing brings into existence a commercially distinct commodity. Mere cleaning, peeling, slicing, packing or sterilising does not by itself amount to manufacture if the commodity retains its commercial identity. Applying that test, pine-apple slices, though processed and packed for sale, remained pine-apple and did not become a different commercial article.

Conclusion: Pine-apple slices were not "other goods" manufactured out of the purchased pine-apple, and section 5A(1)(a) was not attracted.

Final Conclusion: The revision failed and the Tribunal's view that purchase tax was not payable on pine-apple slices was left undisturbed.

Ratio Decidendi: Processing of an article does not amount to manufacture under purchase-tax provisions unless it results in a commercially different commodity with a distinct identity.

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