Job-work manufacture can still count as the dealer's own manufacture for recognition certificate purposes under trade tax law.

A dealer arranging manufacture through job-work by third parties may still be treated as the manufacturer for recognition certificate purposes under trade tax law. Manufacture need not be carried out by the dealer with its own machinery or in its own premises; production through a servant, agent or other party is attributable in law to the dealer. Applying that principle and an earlier binding decision, the Court treated the dealer as the manufacturer despite job-work production and did not sustain cancellation of the recognition certificate.

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Issues: Whether a dealer who gets goods manufactured through other parties on job-work basis can be treated as the manufacturer for the purpose of the recognition certificate under the trade tax law.

Analysis: The revision challenged cancellation of the recognition certificate on the ground that the dealer was not itself manufacturing the goods. The controlling principle applied was that manufacture need not be by the dealer with its own machinery or in its own premises. Where goods are produced through a servant, agent, or third party on job work, the manufacture is treated in law as having been carried on by the dealer. The issue was therefore covered by the earlier binding decision relied upon by the Court.

Conclusion: The dealer was held to be the manufacturer despite production through job work, and the cancellation of the recognition certificate was not sustained.

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