Broad meaning of manufacture under U.P. Trade Tax law brings syrup-to-soft-drink processing within tax as manufactured goods.

Section 2(e-1) of the U.P. Trade Tax Act is framed broadly enough to treat producing, making, altering, processing, treating or adapting goods as manufacture. On the stated facts, converting syrup into a fountain soft drink by using carbon dioxide and a fountain machine was treated as processing that resulted in a taxable manufactured commodity. The principle noted is that manufacture is not limited to the creation of an entirely new commercial product; processing may suffice even where commercial identity is not wholly transformed. The resulting soft drink was therefore treated as a different commodity for tax purposes.

---

---

Issues: Whether converting syrup into fountain soft drink through carbon dioxide and a fountain machine amounts to manufacture under Section 2(e-1) of the U.P. Trade Tax Act, and whether the resulting soft drink is a taxable different commodity.

Analysis: The definition of manufacture under Section 2(e-1) is wide and includes producing, making, altering, processing, treating or adapting goods. On the facts, the syrup was subjected to processing and converted into consumable soft drink through a fountain machine. The controlling principle is that manufacture is not confined to cases where a completely new commercial commodity emerges; processing may amount to manufacture even if commercial identity is not wholly transformed. The Court treated the Tribunal's view as consistent with this statutory width and with the principle that the emergence of a commercially distinct product is not the only test under this provision.

Conclusion: The conversion of syrup into fountain soft drink amounted to manufacture within Section 2(e-1), and the soft drink was rightly taxed as a manufactured commodity.

---