https://www.taxtmi.com/caselaws?id=163121 REP licences were treated as goods, but the Allahabad HC held that their intangible character meant they could not be said to be manufactured within the meaning of the U.P. Trade Tax Act. Manufacture requires a process of producing, making, altering, processing, treating or adapting goods, which presupposes something capable of being worked upon; a licence is issued or granted, not manufactured. As REP licences were not covered by the relevant schedule notification in the year concerned, tax could arise only at the point of sale by the manufacturer or importer. Because the dealer was neither, the sale consideration could not be taxed on that footing, and the later notification was read as consistent with taxation in the hands of the importer or holder. en-us Thu, 09 Mar 2006 00:00:00 +0530 Sat, 22 Mar 2014 12:52:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=163121 REP licences were treated as goods, but the Allahabad HC held that their intangible character meant they could not be said to be manufactured within the meaning of the U.P. Trade Tax Act. Manufacture requires a process of producing, making, altering, processing, treating or adapting goods, which presupposes something capable of being worked upon; a licence is issued or granted, not manufactured. As REP licences were not covered by the relevant schedule notification in the year concerned, tax could arise only at the point of sale by the manufacturer or importer. Because the dealer was neither, the sale consideration could not be taxed on that footing, and the later notification was read as consistent with taxation in the hands of the importer or holder. Case-Laws VAT and Sales Tax Thu, 09 Mar 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=163121