Motor body fixed on chassis not manufacture where both goods retain separate identity and no new commodity emerges.

Mounting a motor body on a chassis with nuts and bolts did not amount to manufacture because the chassis and body remained separately identifiable goods, and removal of the fastening restored their original identity without change in structure, nature or character. The taxing notifications also treated chassis and motor bodies as taxable goods whether sold separately or built on chassis, indicating that the department did not regard the mounted body as a new commodity. On that basis, the process did not create a different commodity, no purchase tax was leviable, and the revision applications were dismissed.

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Issues: Whether mounting or bolting a motor body on a chassis amounted to manufacture so as to create a different commodity and attract purchase tax, and whether the combined sale of chassis and body breached the declaration taken under the exemption notification.

Analysis: The chassis and motor body were separately manufactured goods, and the dealer merely fixed the body on the chassis with nuts and bolts. On removal of the fastenings, the original articles retained their separate identity and no change occurred in their structure, nature or character. The notifications issued under the taxing statute also treated motor bodies and chassis as taxable goods even when built on chassis or sold separately, showing that the department itself did not regard a mounted body as a new commodity. The process therefore did not amount to manufacture and did not result in loss of identity of either article.

Conclusion: The mounting of the motor body on the chassis did not amount to manufacture, no new commodity came into existence, and no purchase tax was leviable; the revision applications were dismissed.

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