Manufacture by processing minerals: crushing Diaspore and Pyrophylite into marketable powder or smaller lumps is manufacture.

Crushing or grinding lumps of Diaspore and Pyrophylite into powder or smaller specified lumps amounts to manufacture because the processed minerals become commercially distinct and marketable products under Section 2(f) of the Central Excises and Salt Act, 1944. The Tribunal found that the mined lumps were not usable in their original form, while the processed forms acquired a different name, character and use for industrial applications. Authorities cited by the appellants were distinguished on their facts and context.

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Issues: Whether crushing or grinding lumps of Diaspore and Pyrophylite into powder or smaller lumps of specified sizes amounts to manufacture under Section 2(f) of the Central Excises and Salt Act, 1944.

Analysis: The minerals in lump form were not usable as mined, but after crushing or grinding they acquired marketability and were used in different industrial applications. The transformed products differed in name, character and use from the mined lumps. The Tribunal relied on the principle that conversion into a commercially distinct and marketable product constitutes manufacture. Authorities cited by the appellants were distinguished on facts and context.

Conclusion: Crushing or grinding of lumps of Diaspore and Pyrophylite into powder or smaller lumps amounts to manufacture under Section 2(f) of the Central Excises and Salt Act, 1944.

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