TMI Blog1997 (11) TMI 113X X X X Extracts X X X X X X X X Extracts X X X X ..... siness of cleaning and repairs of old ornaments. The applicant also buys old ornaments and sells them in the market. The applicant is not engaged in any business as envisaged under Section 2(e-l) of the U.P. Trade Tax Act, 1948 which reads as follows : "`manufacture' means producing, making, mining, collecting, extracting, altering, ornamenting, finishing or otherwise processing, treating, or ad ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be several stages of processing and perhaps a different kind of processing at each stage. With each process suffered, the original commodity experiences a change. But it is only when the change or a series of changes, the commodity to the point where commercially it cannot longer be regarded as the original commodity but instead is recognised as a new and distinct article that a manufacture can be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vities relating to cleaning and tanka are covered by the expression of processing, as such, the same is taxable. 6.The Tribunal has held in its order that the work of cleaning and tanka comes within the definition of manufacture as envisaged under Section 2(e-l) of the U.P. Trade Tax Act. I have carefully considered the submission and the materials on record and find no substance in the submissi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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