Temporary attachment of a compressor to a tractor was not manufacture because no new commercial commodity emerged.

Temporary bolting of a compressor to a tractor for a specific work did not create a new commodity or amount to manufacture under section 2(k), because the two items remained detachable, retained their separate identity, and were shown in bills as distinct commodities. Manufacture requires emergence of a different commercial article from a process, and that test was not met on the facts found. Reassessment and additional tax on the footing of a new taxable commodity were therefore unjustified, and the Tribunal's view that the tractor and compressor continued to retain their separate character was sustained.

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Issues: Whether fixing a compressor to a tractor by bolts for temporary use created a new commodity amounting to manufacture so as to justify reassessment and levy of additional tax.

Analysis: The attachment of the compressor to the tractor was only temporary and was done for a specific work. The two items remained detachable, their identity was not lost, and they were separately shown in the bills as distinct commodities. The statutory concept of manufacture under section 2(k) required emergence of a new commodity through a process that results in a different commercial article. On the facts found, no such new marketable commodity came into existence, and the Tribunal's view that the tractor and compressor continued to retain their separate character was sustained.

Conclusion: The fitting of the compressor did not amount to manufacture, and reassessment on the footing of a new taxable commodity was unjustified.

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