Manufacture requires a new commercial commodity; cutting glass sheets into smaller pieces was held not to qualify.

Cutting glass sheets into strips and pieces of different sizes did not amount to manufacture under section 2(e-1) of the U.P. Sales Tax Act, 1948, because the decisive test is whether the process produces a new commercial commodity. The dealer only reduced the sheets to smaller pieces to meet customer requirements; the glass remained substantially the same goods in form and condition, and no distinct marketable article emerged. Broader authorities on processing did not assist the Revenue on these facts. The revision therefore failed.

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Issues: Whether cutting glass sheets into strips and pieces of different sizes amounts to "manufacture" under section 2(e-1) of the U.P. Sales Tax Act, 1948.

Analysis: The statutory definition of manufacture is wide and includes producing, making, altering, finishing or otherwise processing goods, but the decisive test is whether the activity results in a new commercial commodity. The dealer merely cut glass sheets into smaller pieces according to customer requirements. No different commercial article came into existence, and the glass was sold in substantially the same form and condition after cutting. Authorities relied upon for broader processing did not assist the Revenue because, on the facts here, the activity was only cutting of glass and not transformation into a new marketable commodity.

Conclusion: Cutting of glass sheets into strips and pieces did not amount to manufacture, and the revision failed.

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