Broad definition of manufacture covers yarn sizing processing, supporting concessional tax treatment for raw materials used.

Broadly construed definition of "manufacture" under section 2(k) was held to include processing, and sizing of yarn was treated as a manufacturing process because gum, starch and cellulose derivatives were used as necessary ingredients. On that basis, the materials qualified as raw materials used in manufacture of goods for sale, and defects in registration entries were not fatal where actual use in the process was established. The assessee therefore remained entitled to concessional tax treatment under section 5C(1), and the revisional challenge failed.

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Issues: Whether sizing of yarn amounts to manufacture within the meaning of section 2(k) of the Rajasthan Sales Tax Act, 1954 and whether the assessee was entitled to the concessional rate of tax under section 5C(1) on raw materials used in that process.

Analysis: The expression "manufacture" in section 2(k) was construed broadly so as to include processing. Sizing of yarn was found to be a processing activity in which gum, starch and cellulose derivatives were used as necessary ingredients. The materials were treated as raw materials for manufacturing goods for sale, and the absence or defect in the registration entries was not held fatal where the factual use of the ingredients in the manufacturing process was established.

Conclusion: The assessee was entitled to the benefit of section 5C(1) of the Rajasthan Sales Tax Act, 1954, and the revisional challenge failed.

Ratio Decidendi: Processing that results in a marketable product falls within "manufacture" where the statutory definition is wide enough to include processing, and raw materials actually used in that process qualify for concessional tax treatment under the relevant scheme.

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