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1966 (7) TMI 72

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..... izes of tin-dibbies and the said dibbies are enclosed in cartons made out of box-board or gray-board. Similarly, the boot polish manufactured by the petitioner is covered with aluminium-foils after the same is filled in the dibbies. The petitioner applied before the Sales Tax Officer, Circle II, Gwalior, for inclusion of the tin-plates, labels, aluminium-foils, box-board and grayboard in the regis .....

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..... under rule 8 framed under the M. P. General Sales Tax Act. 2.. Section 8 of the M. P. General Sales Tax Act provides that notwithstanding anything contained but subject to such restrictions and conditions as may be prescribed, the rate of tax payable on the sale to or purchase by a registered dealer of any raw material for the manufacture of other goods for sale in the State of Madhya Pradesh s .....

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..... cles cannot also be included in the definition of "raw material" as they are not used as ingredients in the manufacture of boot polish; nor are they articles consumed in the process of manufacture. It has been observed in Bhartia Electric Steel Co. Ltd. v. Commercial Tax Officer and Others[1956] 7 S.T.C. 527 at p. 535. by Sinha, J.: "The process of manufacture relates to the conversion from the r .....

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..... the facility of sale. The words used in the definition of "raw material" are "an article used as an ingredient in any manufactured goods or an article consumed in the process of manufacture." If the interpretation of the petitioner is accepted, the words used would have been "in connection with or in relation to manufacture of goods". It is, therefore, plain that the contention of the petitioner t .....

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