Broad meaning of "used in manufacture" covers essential ampules for injectable medicines, supporting purchase tax exemption.

The phrase "used in the manufacture" is given a broad meaning that covers the entire integrated process of producing finished goods. Materials essential to completion and marketability, and without which manufacture would be commercially impracticable, fall within that expression. On that reasoning, glass ampules used for washing, sterilisation, filling and sealing injectable medicines are treated as part of the manufacturing process and may be regarded as raw materials rather than mere post-manufacture containers. As a result, their purchase is not subject to purchase tax on the footing that they were used contrary to the declaration in form 19.

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Issues: Whether glass ampules purchased by a pharmaceutical manufacturer and used for washing, sterilisation, filling and sealing of injectable liquid medicines were used in the manufacture of taxable goods for sale so as to avoid purchase tax under the Gujarat Sales Tax Act, 1969, and whether they could be treated as raw materials or consumable stores.

Analysis: The expression "use in the manufacture" was given a broad meaning, extending to the entire integrated process of converting materials into finished goods. Goods required in a process so integrally connected with the ultimate production that, without it, manufacture would be commercially inexpedient, fall within that expression. Applying that test, the ampules were essential to the finished product, since injectable medicine could not safely be marketed, stored or transported unless poured and sealed in ampules. The ampules were therefore part of the manufacturing process and, on common parlance, could properly be regarded as raw materials rather than merely containers used after manufacture was complete.

Conclusion: Glass ampules were used in the manufacture of injections and were liable to be treated as raw materials used for the manufacture of taxable goods for sale. Purchase tax under section 16 was not leviable on their purchase on the footing that they were used contrary to the declaration in form 19.

Ratio Decidendi: The phrase "used in the manufacture" includes every process integrally connected with production, and materials essential to the completion and marketability of the finished product are raw materials used in manufacture for the purpose of purchase-tax exemption.

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