Milling paddy into rice amounts to manufacture, making rice a distinct commodity for purchase tax purposes.

Milling or dehusking paddy into rice is manufacture for purchase tax purposes because the process transforms paddy into a commercially distinct commodity; rice is therefore treated as "other goods" distinct from paddy, and the purchase tax levy under section 5A was justified.

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Issues: Whether the milling or dehusking of paddy into rice amounts to manufacture so as to attract purchase tax under section 5A of the General Sales Tax Act, and whether rice produced from paddy is "other goods" for that purpose.

Analysis: The relevant provision fastens purchase tax where goods liable to tax are consumed in the manufacture of other goods. On the facts, the Court accepted that paddy is consumed in the milling process, but held that the process results in a commercially distinct commodity. The reasoning drew support from the practical commercial identity of rice as a different article from paddy, and from the view that manufacture involves a transformation into a new and different commodity. The contrary decisions and treatise references were considered, but the Court preferred the line of authority treating rice and paddy as distinct commercial commodities for sales tax purposes.

Conclusion: Milling or dehusking paddy into rice is manufacture for the purpose of section 5A, and rice is other goods distinct from paddy. The levy of purchase tax was therefore justified against the assessee.

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