Package tea and blending as manufacture required factual evidence, so the High Court orders were set aside and the matters remitted.

The impugned High Court orders were set aside because the nature of package tea, whether blending tea amounts to manufacture, and whether a distinction exists between packages weighing 27 kgs. or less and those exceeding that weight required factual determination. The matters were remitted for fresh disposal with directions to record oral and documentary evidence on those questions before deciding the writ petitions.

---

---

Issues: Whether the impugned High Court orders should be set aside and the writ petitions remitted for fresh disposal after recording evidence on the nature of package tea, whether blending tea amounts to manufacture, and whether a distinction exists between packages weighing 27 kgs. or less and those exceeding that weight.

Outcome: The impugned High Court orders were set aside and the matters were remitted to the High Courts for fresh disposal after allowing oral and documentary evidence to be recorded on the identified questions of fact.

---