Natural growth is not manufacture: rearing chicks and keeping hens for eggs does not satisfy the statutory test.

Mere rearing of one-day-old chicks into broilers or table birds, and feeding and maintaining laying hens for egg production, does not amount to manufacture under section 2(17) of the Bombay Sales Tax Act, 1959. The statutory concept of manufacture requires producing, making, altering, treating, adapting or otherwise processing goods; ordinary feeding, care, maintenance and collection of eggs are only natural growth or biological processes. As described in the text, the activity lacks the processing or adaptation needed for a legally cognisable manufacturing process.

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Issues: (i) Whether feeding one-day-old chicks and rearing them into broilers or table birds amounted to manufacture under section 2(17) of the Bombay Sales Tax Act, 1959; (ii) Whether feeding and maintaining laying hens for obtaining eggs amounted to manufacture under section 2(17) of the Bombay Sales Tax Act, 1959.

Issue (i): Whether feeding one-day-old chicks and rearing them into broilers or table birds amounted to manufacture under section 2(17) of the Bombay Sales Tax Act, 1959.

Analysis: The statutory definition of manufacture is wide, but it still requires the activity to amount to producing, making, altering, treating, adapting, or otherwise processing goods. Mere rearing of chicks with ordinary care, feeding, and maintenance in sanitary conditions does not itself alter or adapt the chicks into broilers. Even if a broiler is commercially distinct from a young chick, the process of rearing remains a natural growth process and not a manufacturing activity.

Conclusion: The activity of rearing chicks into broilers does not amount to manufacture.

Issue (ii): Whether feeding and maintaining laying hens for obtaining eggs amounted to manufacture under section 2(17) of the Bombay Sales Tax Act, 1959.

Analysis: Eggs are produced by the natural biological process of a hen laying eggs. Keeping hens in good health, feeding them, collecting the eggs, preserving them, and selling them does not amount to the keeper producing the eggs by any manufacturing process. The activity does not involve any processing, treatment, or adaptation of goods within the meaning of the definition.

Conclusion: The activity of keeping laying hens and collecting their eggs does not amount to manufacture.

Final Conclusion: Both questions were answered in favour of the revenue, and the reference was disposed of accordingly.

Ratio Decidendi: An activity amounts to manufacture only if it involves one of the statutory modes of production or processing and results in a legally cognisable manufacturing process, not merely the natural growth or biological production of goods.

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