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    <title>2015 (1) TMI 132 - GAUHATI HIGH COURT</title>
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    <description>Purification of raw water into packaged drinking water does not amount to manufacture where the process does not create a distinct commercial commodity with a changed identity, nature or character. Applying the statutory test under the Assam tax laws, the court noted that the water remained water, with its essential use unchanged, and that the process only improved quality. Earlier decisions on comparable processing, including filtration of raw mustard oil, were treated as supporting the same principle. The challenge to the impugned order failed, and the Revenue&#039;s position was upheld. The question of cancellation of eligibility certificates on a mere change of opinion was left for the competent authority to examine in accordance with law.</description>
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      <description>Purification of raw water into packaged drinking water does not amount to manufacture where the process does not create a distinct commercial commodity with a changed identity, nature or character. Applying the statutory test under the Assam tax laws, the court noted that the water remained water, with its essential use unchanged, and that the process only improved quality. Earlier decisions on comparable processing, including filtration of raw mustard oil, were treated as supporting the same principle. The challenge to the impugned order failed, and the Revenue&#039;s position was upheld. The question of cancellation of eligibility certificates on a mere change of opinion was left for the competent authority to examine in accordance with law.</description>
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