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Ujagar Prints v. Union of India and Ors. , Empire Industries Ltd. v. Union of India , South Bihar Sugar Mills Ltd. v. Union of India .
Manufacturing implies a change and there must be transformation, a new and different article emerging with a distinctive name, character or use, Grey fabric, after undergoing various processes of bleaching, dyeing, sighing, printing, finishing, etc. merges as a commercially different commodity with its own price structure, customs and other commercial incidents, involving 'manufacture'.
Business of extraction of granite cutting, polishing and conversion into slabs amounts to manufacture and production of an article or thing entitled to investment allowance as the same involves manufacturing.
4.4 It is evident from the above discussion that if the following tests are satisfied then one can say that there is manufacture or production:
(i) There is a change or transformation of one commodity into another, (ii) The two commodities are commercially different and distinct.
(iii) The resultant commodity emerging out of the process should have a distinct name, character or use.
(iv) All the changes and mere change of size does not tantamount to manufacture and the change should be such as to bring into existence a new commodity having a different identity.

13. From various definitions and decisions, it finally emerges that if the following tests are satisfied by the assessee, then it can be said that there is a 'manufacture' or 'production'. These tests are that:

(i) there is a change or transformation of one commodity into another; (ii) the two commodities are commercially different and distinct;

10. From the decision cited by the senior Departmental Representative, we find that in certain cases certain processes involved have been treated as 'manufacture'. For example 1982 ELT 253 (Teleprinter in sub-item (ii) Tariff Item 17 is a distinct entry) 1987 ELT 389 (the product viz. circles fully specified the description contained in Item 26A(2), (iii) 1980 ELT 735. But those were instances where the article or product was covered under a specific Tariff entry. As rightly pointed out by the learned Counsel for the respondents, the product now in question, before and after the said process of sawing, are not so different and distinct that it could be said that, in commercial parlance, commodity was converted into another commercially distinct and different commodity.