Acit, Circle - 41, Kolkata, Kolkata vs M/S. Anmol Textiles,, Kolkata on 17 April, 2018
In the decision reported in Aspinwall & Co. Ltd. (supra), the Apex Court
observed "It is to be understood as meaning the production of articles for use from raw
or prepared materials by giving such materials new forms, qualities or combinations
whether by hand labour or machines. If the change made in the article results in a new
and different article 'then it would amount to manufacturing activity". Thus the Apex
Court pointec out that if the commodity can no longer be regarded as the original
commodity but instead is recognized as a new and distinct article, then the activity of
manufacture can be said to take place.