Wide statutory definition of manufacture covers conversion of iron scrap into ribbed bar, even through another agency.

The special definition of "manufacture" in section 2(j) of the M.P. General Sales Tax Act, 1958 governed the issue, and conversion of iron scrap into ribbed bar fell within that enlarged definition. The fact that the processing was carried out through another agency did not change the character of the process, because the statutory definition focused on the nature of the activity rather than who performed it. The process was therefore manufacture, and the question was answered in favour of the assessee. The second referred question was left unanswered as unnecessary for disposal of the reference.

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Issues: Whether the drawing of ribbed bar from iron scrap amounted to manufacture for the purposes of the M.P. General Sales Tax Act, 1958, even where the processing was got done through another agency.

Analysis: The governing test was the special and enlarged definition of "manufacture" in section 2(j) of the M.P. General Sales Tax Act, 1958, which includes not only making goods but also other specified processes. On that statutory definition, the conversion of iron scrap into ribbed bar fell within manufacture. The place where the process was carried out, or whether it was done through another agency, did not alter the character of the process itself. The second referred question was not answered as it was considered unnecessary for disposal of the reference.

Conclusion: The drawing of ribbed bar from iron scrap amounted to manufacture, and the question was answered in favour of the assessee.

Ratio Decidendi: Where a taxing statute contains a wide and special definition of manufacture, the statutory definition prevails and a process falling within that definition is manufacture irrespective of whether the process is carried out by the dealer itself or through another agency.

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