Broad definition of manufacture brought coal briquettes within tax net as processing and adaptation of coal

Coal briquettes made from coal were treated as manufactured goods under the U.P. Trade Tax Act because the statutory definition of manufacture was broad and included processing, treating and adapting goods. The Court relied on the width of that definition and on the principle that a change in commercial identity is not decisive where the statute uses expansive language. On that basis, conversion of coal into briquettes was held to be manufacture, and the briquettes were liable to tax. The revisions were dismissed.

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Issues: Whether coal briquettes manufactured from coal were exigible to tax under the U.P. Trade Tax Act, and whether the activity amounted to manufacture.

Analysis: The definition of manufacture under the U.P. Trade Tax Act was broad and included processing, treating and adapting goods. The Court relied on the width of that definition and on the Supreme Court's exposition that commercial identity of the goods was not decisive where the statutory definition is expansive. The conversion of coal into briquettes was treated as a process of treating or adapting the raw material and therefore fell within the statutory meaning of manufacture.

Conclusion: Coal briquettes were held to be the result of manufacture and were liable to tax; the revisions were dismissed.

Ratio Decidendi: Where the statutory definition of manufacture is inclusive and wide, a process that processes, treats or adapts goods constitutes manufacture even if the original commercial identity of the goods is not wholly altered.

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