Manufacture for sales tax exemption requires a commercially distinct product; crushing raw bones did not qualify.

Conversion of raw bones into crushed bones does not amount to manufacture where manufacture under the exemption notification requires a transformation into a commercially different commodity. On that basis, the process did not satisfy the statutory and notification-based definition of manufacture, and sales tax exemption was unavailable. The rejection orders were also upheld because they referred to the assessee's activity and the governing legal position, providing sufficient reasons to sustain the administrative decision. The key principle is that an exemption notification defining manufacture must be strictly construed, and mere crushing or similar processing without commercial distinctness does not qualify.

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Issues: (i) Whether converting raw bones into crushed bones amounts to manufacture so as to attract sales tax exemption under Notification S.R.O. No. 1729 of 1993. (ii) Whether the rejection orders were invalid for want of reasons.

Issue (i): Whether converting raw bones into crushed bones amounts to manufacture so as to attract sales tax exemption under Notification S.R.O. No. 1729 of 1993.

Analysis: Manufacture requires that raw materials undergo a transformation resulting in a commercially different commodity. The notification itself defines manufacture in that sense and the exemption must be strictly construed. Conversion of raw bones into crushed bones does not bring into existence a commercially distinct product. The activity therefore does not satisfy the statutory and notification-based meaning of manufacture.

Conclusion: The conversion of raw bones into crushed bones is not manufacture, and the assessee is not entitled to exemption under Notification S.R.O. No. 1729 of 1993.

Issue (ii): Whether the rejection orders were invalid for want of reasons.

Analysis: The orders referred to the assessee's activity and relied on the governing legal position that conversion of bones into bone meal does not amount to manufacture. The rejection was therefore supported by reasons sufficient to sustain the administrative decision.

Conclusion: The orders were not invalid as non-speaking or cryptic orders.

Final Conclusion: The assessee's claim for sales tax exemption failed, and the refusal of exemption was upheld.

Ratio Decidendi: For an exemption notification defining manufacture, only a process producing a commercially different commodity from the raw material qualifies as manufacture; mere crushing or similar conversion without such change does not.

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