Packing or re-packing detergent powder is not manufacture when the product retains its essential character under sales tax law.

Packing or re-packing loose detergent powder into unit containers did not amount to manufacture under section 2(22) of the Assam General Sales Tax Act, 1993. Although the statutory definition of manufacture was broad, it still required a process that brought into existence a product materially different from the original input. Because detergent powder retained its essential character and no new commodity emerged, the packaged product remained detergent powder. The earlier view treating such packing activity as manufacture was inconsistent with that interpretation, so the sales tax levy on that basis was unsustainable.

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Issues: Whether packing or re-packing loose detergent powder into unit containers amounts to "manufacture" within section 2(22) of the Assam General Sales Tax Act, 1993, so as to attract levy of sales tax on the packaged product.

Analysis: The definition of "manufacture" under section 2(22) of the Assam General Sales Tax Act, 1993 was treated as wide, but it still required the activity to bring into existence a product noticeably different from the original input. Applying that principle, the process of packing or re-packing detergent powder did not change its essential character. No new commodity came into existence and the end product remained detergent powder. The prior view treating the process as manufacture was inconsistent with the governing interpretation already applied by the Court in relation to the statutory definition.

Conclusion: Packing or re-packing detergent powder did not amount to manufacture under section 2(22) of the Assam General Sales Tax Act, 1993, and the levy based on that premise was unsustainable.

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