Mere cutting of newsprint does not amount to manufacture where no new commercial commodity emerges.

Cutting odd-size newsprint into smaller sizes and reselling it did not amount to manufacture of writing paper because no commercially different commodity emerged; the goods remained newsprint, already taxed at the earlier point of sale. Mere size reduction was insufficient to create a new taxable product, so the finding that the assessee was a manufacturer of writing paper could not be sustained. The revision was allowed, the impugned order was set aside to that extent, and the matter was remitted for appropriate action under Section 11(8).

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Issues: Whether cutting odd-size newsprint into a smaller size and reselling it as newsprint amounted to manufacture of writing paper so as to attract sales tax.

Analysis: The assessee purchased odd-size newsprint and only cut it into smaller sizes before resale. No commercially different commodity emerged from this process. The commodity remained newsprint and had already suffered sales tax at the earlier point of sale. Mere cutting to a different size did not amount to manufacture of a new taxable product.

Conclusion: The finding that the assessee was a manufacturer of writing paper could not be sustained. The revision was allowed, the impugned order was set aside to that extent, and the matter was remitted for appropriate action under Section 11(8).

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