Iron wire from iron rods is not a separate taxable commodity when drawing does not amount to manufacture.

Iron wire drawn from iron rods was held not to be a separate commodity for sales tax purposes because the drawing process did not amount to manufacture. The Court treated iron rods and iron wires as one and the same commodity, noting their joint coverage under Section 14 of the Central Sales Tax Act, 1956 and relying on the definition of manufacture under the U.P. Trade Tax Act, 1948. As no distinct commercial product emerged from the process, the wire could not be subjected to separate tax over and above the tax already paid on the iron rods.

---

---

Issues: Whether iron wire obtained from iron rods is a separate and distinct commodity from iron rods so as to be separately taxable.

Analysis: The question turned on whether the process of drawing wire from iron rods brings into existence a distinct for tax purposes. The Court noted that the goods were covered together under Section 14 of the Central Sales Tax Act, 1956 and relied on the earlier view that iron rods and iron wires are one and the same commodity. It further considered the definition of manufacture in Section 2(e-1) of the U.P. Trade Tax Act, 1948 and held that extraction of wire from iron rods does not amount to manufacturing activity sufficient to treat the two as different commodities.

Conclusion: Iron wire drawn from iron rods is not a separate and distinct commodity and cannot be taxed separately over and above the tax already paid on iron rods.

Ratio Decidendi: Where the process only results in extraction of wire from iron rods and does not amount to manufacture, the goods remain the same commodity for sales tax purposes and are not separately exigible as distinct items.

---