Manufacture under GST requires a new product; limestone processing remained a service, not goods supply.

Crushing, screening and sizing of limestone/dolomite does not constitute manufacture under section 2(72) of the CGST Act because the process only alters physical dimensions and does not create a new product with a distinct name, character and use. The mineral's identity, chemical composition and commercial nomenclature remain unchanged, and marketability alone is insufficient to satisfy the statutory test. The contractor's commercial or operational risk does not alter the GST character of the activity. Processing applied to another person's goods is treated as a supply of service under Schedule II, so the activity is classified as a service rather than manufacture.

---

---

Issues: Whether crushing, screening and sizing of limestone/dolomite by the contractor amounts to manufacture under section 2(72) of the CGST Act, 2017.

Analysis: Manufacture under section 2(72) requires processing of raw material resulting in a new product having a distinct name, character and use. The activity in question only changes the physical dimensions of limestone/dolomite; the mineral identity, chemical composition and commercial nomenclature remain the same before and after processing. Marketability alone does not satisfy the statutory test. The mere fact that the contractor bears commercial or operational risk does not change the character of the activity, because classification under GST depends on the nature of the process actually performed. Treatment or process applied to another person's goods is treated as a supply of service under Schedule II.

Conclusion: The activity does not amount to manufacture and is not a supply of goods on that basis. The answer is negative and is against the assessee.

Final Conclusion: The ruling treats the activity as processing on another person's goods rather than manufacture, so the GST classification remains within the service category.

Ratio Decidendi: An activity is manufacture only if processing brings into existence a new product with a distinct name, character and use; mere physical alteration of the same commodity, even if marketable, is insufficient, and contractual risk allocation does not alter GST classification.

---