Chemically treated rubber wood qualifies as manufacture, making pre-1998 sales tax exemption available under the notification.

Chemically treated rubber wood was held to amount to manufacture under Notification S.R.O. No. 1729 of 1993 because the processing went beyond preservation and produced a commercially distinct timber product with greater durability, strength and utility. The Court found that raw rubber wood and treated rubber wood had different character, use and market value, and that the later amendment in S.R.O. No. 295 of 1998 was clarificatory. It also noted that similarly placed units had received the exemption, making a contrary view discriminatory. The exemption was therefore available for the period before 1 April 1998.

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Issues: Whether chemically treated rubber wood amounts to manufacture under Notification S.R.O. No. 1729 of 1993 and is eligible for sales tax exemption for the period prior to 1 April 1998.

Analysis: The notification defined manufacture as use of raw materials resulting in goods commercially different from the raw materials, while excluding mere preservation or processes that do not bring about a distinct commercial product. The process applied to raw rubber wood involved substantial chemical treatment and curing, not a mere preservative treatment. Raw rubber wood was usable only as firewood, whereas the treated product acquired durability, strength, and utility as timber for furniture-making. The trade and market understood the treated product as a separate commodity with a different character, use, and value. The later amendment by S.R.O. No. 295 of 1998 was treated as clarificatory in nature, and the Court also noted that similarly placed units had been granted the benefit, making a contrary view discriminatory.

Conclusion: Chemically treated rubber wood is manufacture even prior to 1 April 1998, and the appellant is entitled to the exemption under Notification S.R.O. No. 1729 of 1993.

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