Raw materials under sales tax law must form the finished product, not merely assist manufacturing process.

Goods used in manufacturing are not treated as raw materials under section 5(2)(a)(ii) of the Bengal Finance (Sales Tax) Act, 1941 unless they are material from which the finished product is made. The Delhi High Court's reasoning, as described, applied the ordinary meaning of "raw materials" and rejected importation of the broader language of section 8(3)(b) of the Central Sales Tax Act, 1956 and rule 13 of the Central Sales Tax (Registration and Turnover) Rules, 1958. Oxygen gas, calcium carbide, electrodes and acetylene gas were used in the manufacturing process but did not become part of, or transform into, the finished goods, so their inclusion in the dealer's registration certificate was not justified.

---

---

Issues: Whether oxygen gas, calcium carbide, electrodes and acetylene gas could be treated as raw materials within section 5(2)(a)(ii) of the Bengal Finance (Sales Tax) Act, 1941, as extended to the Union Territory of Delhi, for inclusion in the dealer's registration certificate.

Analysis: The provision, as amended in 1959, confined the benefit to goods used by a registered dealer as raw materials in the manufacture of goods for sale. The expression was held not to extend to every item used in the manufacturing process. In the absence of a statutory definition, the words were to be understood in their ordinary or dictionary sense, meaning material from which the finished product is made. The wider language of section 8(3)(b) of the Central Sales Tax Act, 1956, read with rule 13 of the Central Sales Tax (Registration and Turnover) Rules, 1958, could not be imported to enlarge the local Act. The items claimed were found to be used in the manufacturing process, but not to become part of, or to be converted into, the finished goods.

Conclusion: The items were not raw materials within section 5(2)(a)(ii) of the Bengal Finance (Sales Tax) Act, 1941, and their inclusion in the registration certificate was not justified.

---