Blending asafoetida with fillers does not constitute manufacture when no new commodity emerges.

Blending raw asafoetida with wheat flour and gum Arabic did not amount to manufacture because the process caused no chemical change and produced no new commercially distinct commodity. The added ingredients functioned only as fillers and did not alter the essential character of the asafoetida. Mere conversion from raw form to lump or powder was held insufficient to constitute manufacture, and the position was distinguished from cases where processing created a separate marketable product.

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Issues: Whether the process of compounding or blending raw asafoetida with wheat flour and gum Arabic amounts to manufacture.

Analysis: The process involved only blending the raw asafoetida with wheat flour and gum Arabic, with no chemical change and no emergence of a new commodity. The added ingredients acted as fillers and did not alter the essential character of the asafoetida. The conversion from raw form to lump or powder, by itself, was insufficient to constitute manufacture. The facts were distinguishable from cases where processing produced a commercially separate and distinct product.

Conclusion: The process does not amount to manufacture and the assessee succeeds on this issue.

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