Refrigerated cold storage is not processing of goods; concessional electricity duty under the notification was denied.

A cold storage undertaking preserving goods by refrigeration was held not to be engaged in processing goods for purposes of a notification granting concessional electricity duty. Applying the ordinary commercial meaning of an undefined expression, and relying on prior decisions, the Court treated mere preservation of perishable goods without transformation as neither manufacture nor processing. On that basis, refrigeration-based storage did not fall within the notification, and the undertaking was not entitled to the reduced duty.

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Issues: Whether a cold storage undertaking engaged in preserving goods by refrigeration could be treated as engaged in the processing of goods and thus fall within the notification granting concessional electricity duty.

Analysis: The relevant notification was construed in the light of prior decisions holding that mere storage of perishable goods under refrigeration does not amount to processing of goods. The Court applied the principle that, where the statute or notification does not define the expression, commercial meaning is to be adopted, and preservation by refrigeration without a transformation of the goods does not constitute manufacture or processing.

Conclusion: The cold storage activity was not a process of goods within the meaning of the notification, and the respondent was not entitled to the reduced electricity duty.

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