Expansive definition of manufacture covers marble crushing and grinding for marketable powder, supporting tax exemption eligibility.

Crushing and grinding marble stones into marble powder was held to fall within the expansive inclusive definition of "manufacture" in section 2(j) of the M.P. General Sales Tax Act, 1958, because the process prepared goods for marketability even though it did not create a commercially new article. The Court applied the statutory wording and prior authorities to reject the narrower common-law meaning of manufacture. On that basis, refusal to issue the eligibility certificate was unsustainable, the impugned order was quashed, and the respondent was directed to grant the certificate and consequential exemption according to law.

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Issues: Whether crushing marble stones and converting them into marble powder amounts to "manufacture" within the meaning of section 2(j) of the M.P. General Sales Tax Act, 1958, and whether the petitioner was entitled to an eligibility certificate for tax exemption.

Analysis: The statutory definition in section 2(j) is of wide amplitude and includes any process of producing, collecting, extracting, preparing or making goods. Earlier decisions under the Act and the later Supreme Court authorities were applied to hold that the narrow common-law meaning of manufacture is not controlling under this special definition. The making of marble powder by crushing and grinding marble stones is a process of preparing goods for the market and falls within the inclusive statutory meaning of manufacture.

Conclusion: The activity amounts to manufacture under section 2(j), and the refusal to grant the eligibility certificate was unsustainable.

Final Conclusion: The petition succeeded, the impugned order was quashed, and the respondent was directed to grant the eligibility certificate and consequential exemption in accordance with law.

Ratio Decidendi: Where a fiscal statute gives an expansive inclusive definition of manufacture, any process that prepares goods for marketability may constitute manufacture even if it does not create a commercially new article.

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