https://www.taxtmi.com/caselaws?id=161350 An executive clarification cannot alter the meaning of "manufacture" in a sales tax exemption notification, because the notification must be construed on its own terms and only a statutory amendment can change its legal effect. The controlling test is whether processing produces a commercially different commodity by change in name, character or use, rather than a mere preservation-type activity. On that basis, chemical treatment of rubber wood required factual examination of the trade identity of the end product and could not be conclusively determined on the existing record. The clarification and consequential orders were set aside, and the exemption claim was remitted for fresh decision under the statutory procedure. en-us Mon, 05 Aug 2002 00:00:00 +0530 Thu, 16 Jan 2014 12:22:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=161350 An executive clarification cannot alter the meaning of "manufacture" in a sales tax exemption notification, because the notification must be construed on its own terms and only a statutory amendment can change its legal effect. The controlling test is whether processing produces a commercially different commodity by change in name, character or use, rather than a mere preservation-type activity. On that basis, chemical treatment of rubber wood required factual examination of the trade identity of the end product and could not be conclusively determined on the existing record. The clarification and consequential orders were set aside, and the exemption claim was remitted for fresh decision under the statutory procedure. Case-Laws VAT and Sales Tax Mon, 05 Aug 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=161350