Manufacture under trade tax law extends to converting concentrate into aerated drinks with distinct commercial identity.

Dilution of cold drink concentrate by adding water and gas to produce aerated drinks was treated as manufacture under the U.P. Trade Tax Act, 1948 because the statutory definition is broad and covers processing, adapting and altering goods. The court applied the commercial identity and common parlance tests and found that the finished aerated drink was a distinct commodity, not synonymous with the original concentrate. Authorities cited by the revisionist were distinguished on the ground that they involved situations where no separate commercial product emerged. The Tribunal's view was therefore upheld and the revisions were dismissed.

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Issues: Whether dilution of cold drink concentrate by adding water and gas to produce aerated drinks amounts to manufacture under the U.P. Trade Tax Act, 1948.

Analysis: The definition of manufacture under the Act is expansive and includes producing, making, altering, finishing, processing, treating or adapting goods. The revisionist's product underwent a process that converted cold drink concentrate into an aerated drink having a distinct commercial identity and a different form from the original concentrate. On commercial and common parlance tests, the two are not identical or synonymous commodities. The authorities relied upon by the revisionist were distinguished because they dealt with factual situations where no distinct commercial commodity emerged.

Conclusion: The activity amounted to manufacture, and the Tribunal's view called for no interference. The revisions were dismissed.

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