Timber conversion into planks or firewood qualifies as manufacture, supporting Wealth-tax exemption for the assessee.

Conversion of timber logs into planks or firewood in a saw mill was treated as manufacture, because the process by manual labour or mechanical means produced a new and different substance distinct from the original logs. On that basis, the activity also amounted to processing of articles for the purpose of the exemption under section 5(1)(xxxi) of the Wealth-tax Act. The assessee, engaged in timber dealing and such conversion, was therefore entitled to the exemption.

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Issues: Whether conversion of logs into planks or firewood in a saw mill amounted to manufacture or processing of articles so as to entitle the assessee to exemption under section 5(1)(xxxi) of the Wealth-tax Act.

Analysis: The assessee was engaged in dealing in timber and converted logs into planks or firewood by manual labour or mechanical process. Such conversion results in a new and different substance, and the resulting planks and firewood are distinct articles from the original logs. The process therefore falls within the meaning of manufacture, and the exemption was available.

Conclusion: The assessee was entitled to exemption under section 5(1)(xxxi) of the Wealth-tax Act.

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