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The relevant portion of the judgement is being quoted below:-

"The Tribunal held that in this process assessee was involved in the activity of manufacturing the coffee beans from the raw material plucked from the plant.
The High Court accepted the factual matrix but in conclusion as to whether it amounts to manufacturing activity differed with the Tribunal and held (page 930):
"We find that all the nine stages of the process do not show any kind of change or a commercially different commodity is not seen to be passing through the various stages of the process. It cannot be ignored that in common parlance, 'coffee' means, coffee powder, a beverage consumed as either a hot or cold drink. At no stage, this colour combination between manufacture and production has its manifestation".

The submission of the learned counsel for the Revenue that the assessee was doing only the processing work and was not involved in the manufacture and producing of a new article cannot be accepted. The process is a manufacturing process when it brings out a complete transformation in the original article so as to produce a commercially different article or commodity. That process itself may consist of several processes. The different processes are integrally connected which results in the production of a commercially different article. If a commercially different article or commodity results after processing then it would be a manufacturing activity. The assessee after processing the raw berries converts them into coffee beans which is commercially different commodity. Conversion of the raw berry into coffee beans would be a manufacturing activity.

"Manufacture" (Verb)-bring (Material) into from fit for use; produce (articles) by labour esp. by machinery on large scale.

23. In CIT Vs. Tax Locomotive and Engg. Co. (1968) 68ITR 325, assembling of automotive bus or truck chassis from component parts, so as to convert into an automobile has been held to amount to manufacture.

24. Blending of different kinds of ore possessing different chemicals and physical composition, in order to produce ore of a particular specification has not been considered/held as a "Manufacture" operation because commercially no new and distinct commodity from the original ore of different specification has been produced/manufactured although the entire activity of the assessees was brodly divisible into seven different operations; such as dressing, washing, ore handling, screening and blending it etc. See Chowgule and Co. (P) Ltd. Vs. UOI-AIR 1981 SC 1014.