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Again, in the course of the judgment, it was observed:

Wherever a commodity undergoes a change as a result of some operation performed on it or in regard to it, such operation would amount to processing of the commodity.

The Supreme Court also observed:

What is necessary in order to characterise an operation as 'processing' is that the commodity must, as a result of the operation, experience some change.

When the chemical and physical composition of each kind of ore which goes into the blending is changed, there can be no doubt that the operation of blending would amount to 'processing' of ore within the meaning of Section 8(3)(b) of the Central Sales Tax Act and Rule 13 which were for consideration before the Supreme Court in that case. While considering the question whether machinery, vehicles, barges and other items of goods purchased by the assessee for using at the mining site, conveying the ore from the mining site to the river side and carrying it by barges to the Marmugoa harbour, fell within the description of processing of ore within Section 8(3)(b) and Rule 13, it was held that if any of these items of goods were purchased by the assessee as being intended for use as 'machinery, plant, equipment, tools, spare pans, stores, accessories, fuel or lubricants' in carrying the mined ore from the mining site to the river side and from river side to the Marmugoa harbour, they would qualify for inclusion in the Certificate of Registration. Mr. Mehta appearing for the respondents has urged before us that this portion of the judgment of the Supreme Court in Chowgule & Co.'s (supra) which deals with the question of transporting of iron ore from the mining site to the river side and from the river side to Marmugoa harbour where the goods were shipped, would qualify for inclusion in the Certificate of Registration, indicates that even transporting of goods, that is, iron ore, from one place to another would amount to processing to some extent because the requisite words were "goods intended for use in processing of ore for sale." It must not be forgotten that in that particular case of Chowgule & Co. The Supreme Court came to the conclusion that blending of iron ore in the course of loading through mechanical ore handling plant would amount to processing under Section 8(3)(b) read with Rule 13 which was before the Supreme Court and since transporting was for the purpose of processing through mechanical ore-handling plant, all those vehicles were also held to have been used for processing iron ore in that particular case.