Coal beneficiation and cost audit: wet-process washing may qualify as manufacture, but process-specific evidence remains decisive

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....Coal beneficiation through wet process is discussed as yielding a commercially improved output and, on the authorities cited, may fall within manufacture or production for purposes of cost records and cost audit under the Companies (Cost Records and Audit) Rules, 2014. The text notes that manufacture requires a transformation into a new and different article with a distinctive name, character and use, but whether a particular beneficiation process retains the original character of coal or is only processing depends on the actual facts and evidence, making the defence a mixed question of fact and law.....