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29. In the case of Chowgule & Co. Pvt. Ltd. v. Union of India , it has been held by the Supreme Court that though the blending of different qualities of ore possessing differing chemical and physical composition so as to produce ore of contractual specifications cannot be said to involve the process of manufacture, since the ore that is produced cannot be regarded as a commercially new and distinct commodity form the ore out of different specifications blended together, the operation of blending would amount to "processing" of ore. For the same very reason, it can conveniently be held that the blending of different kinds and varieties of tea to provide a balance in terms of flavour, strength and colour is only a processing of the tea to suit the demands of a particular class of consumers. Mere blending of the tea by itself cannot be characterised as manufacturing of a different commercial product. Further, as noticed above, the tea so blended in the industrial unit of the petitioner through mechanical process is subjected to hi-tech packaging machines to pack and seal in consumer packs of various sizes in a synchronised manner.

On a consideration of the matter, we are persuaded to think that the view taken in the Empire Industries' case ; AIR 1989 SC 662 that 'grey fabric' after it undergoes the various processes of bleaching, dyeing, sizing, printing, finishing, etc., emerges as a commercially different commodity with its own price structure, custom and other commercial incidents and that there was in that sense a 'manufacture' within the meaning of section 2(f), even as unamended, is an eminently plausible view and is not shown to suffer from any fallacy."

48. The pronouncement of law by the five-Judges Bench of the Supreme Court in Ujagar Print's case AIR 1989 SC 516 is obviously indicative of a more liberal, appropriately deviated and widening judicial concept of the word "manufacture". In the said case, keeping in view the varied and multifarious aspects of the present day industrialisation, the Supreme Court took note of the price structure, custom and other commercial incidents of the industrial product for identifying it as a commercially different commodity. This is a clear indication of setting of a new dimension to the word "manufacture" which, to meet the present industrial concepts, is much needed. The said word has to embrace new shades and ingredients to its meaning because of the induction of the hi-tech concepts in the industrial world as has been recognised even in the impugned industrial policy notification of the Government.