Manufacture requires a new commercially distinct product; repacking minced tobacco with flavouring was not enough.

Purchasing minced tobacco in bulk, repacking it into smaller packs, and adding flavour or scent does not amount to manufacture unless the process creates a commercially distinct commodity. The stated principle is that manufacture requires a change in character, identity, or use, not merely a variation in form or packaging. On the facts described, the tobacco retained its identity as the same product despite repacking and flavouring, so no new commercial product came into existence. The tax demand based on treating that activity as manufacture could therefore not be sustained.

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Issues: Whether purchasing minced tobacco in bulk, repacking it in smaller packs, and adding flavour or scent amounts to manufacture under Section 2(27) of the Tamil Nadu Value Added Tax Act, 2006.

Analysis: Manufacture requires a process that brings into existence a commercially different and distinct commodity. On the facts found, the minced tobacco was only repacked in smaller quantities with some flavour or scent added, but its identity remained unchanged and it did not become a new commercial product. The principle applied was that every change is not manufacture, and the process must result in a product with a different character and use.

Conclusion: The activity did not amount to manufacture and the tax demand based on that premise could not be sustained.

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