Manufacture requires a new commercial product; cleaning and cutting waste fibre alone was insufficient under sales tax law.

Cleaning and washing waste fibre with chemicals, followed by cutting it into pieces, was held not to amount to manufacture under section 2(j) of the M.P. General Sales Tax Act, 1958, because the process did not bring into existence a new commercial commodity with a distinct identity. The court reasoned that the definition of manufacture is wide, but it still requires transformation into a different product; merely removing dirt, improving condition, or enhancing value while the material remains essentially the same article is insufficient. The Tribunal's view was therefore rejected, and the process was treated as outside the scope of manufacture.

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Issues: Whether cleaning and washing waste fibre with certain chemicals and cutting it into pieces amounts to manufacture within section 2(j) of the M.P. General Sales Tax Act, 1958.

Analysis: The definition of manufacture in section 2(j) is wide, but it still requires a process that brings into existence a new product or a different commercial commodity. Mere cleaning of waste fibre to remove dirt and foreign matter, followed by cutting it into pieces and selling it as staple fibre base, does not by itself change the essential identity of the goods. The process only improves the condition or value of the goods and does not amount to manufacture where the material remains the same commercial article.

Conclusion: The Tribunal was not justified in holding that the process amounted to manufacture; the reference was answered in favour of the assessee.

Ratio Decidendi: A process amounts to manufacture only if it brings into existence a new commercial product with a distinct identity, and mere cleaning, washing, or cutting that leaves the goods essentially the same does not constitute manufacture.

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