Blending and packing of tea is not manufacture where the product retains the same commercial identity.

Blending and packing of tea does not amount to manufacture under the U.P. Trade Tax Act because manufacture requires the emergence of a new commercial commodity. If the processed product retains the same commercial identity in market parlance, the activity remains outside manufacture. On that principle, tea continues to be tea after blending and packing, so no new commodity comes into existence. The issue is therefore resolved in favour of the assessee.

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Issues: Whether blending and packing of tea amounts to manufacture under the U.P. Trade Tax Act.

Analysis: Manufacture requires the emergence of a new commercial commodity. Where the processed goods retain the same commercial identity and remain the same commodity in market parlance, the activity does not amount to manufacture. Applying that principle, blending and packing of tea does not produce a new commodity, because tea continues to remain tea even after the process.

Conclusion: Blending and packing of tea does not amount to manufacture, and the issue is decided in favour of the assessee.

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