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Deputy Commissioner, Sales Tax (Law) ... vs Pio Food Packers on 9 May, 1980

23. There are no two opinions about the proposition of law laid down by the apex court in the above referred cases. Applying the same in the instant petitions it is clear that the process through which 'Pan Masala' and other products of like nature are prepared brings into existence a new substance known as 'Pan Masala' etc. and it is not that it produces only some change in a substance. As stated above before this process Betel nuts, Lime, Catechu, Cardamom, Menthol etc. remain different substances but as a result of that process it brings into existence a new substance known as 'Pan Masala' etc. Thus, the transformation does take place and a new and different article does emerge having a distinctive name and character.
Supreme Court of India Cites 9 - Cited by 305 - R S Pathak - Full Document

S.P.S. Jayaram & Co. vs Assistant Collector Of Central Excise ... on 25 June, 1986

In the instant case also 'Pan Masala' and other products of like nature are manufactured from betel nuts and other components but as a result of the process betel nuts and other components are transformed into 'Pan Masala' and other products of like nature and the components lose not only its identity but also its commercial name, character and use, therefore, the ratio laid down in aforesaid case is fully applicable to the instant case.
Madras High Court Cites 26 - Cited by 2 - Full Document

Ashok Griha Udyog Kendra Pvt. Ltd. vs Collector Of Central Excise And Customs on 5 March, 1982

In Ashok Griha Udyog Kendra Pvt. Ltd., Kanpur v. Collector of Central Excise and Customs, Kanpur -1982 (10) E.L.T 309 (All), the Division Bench of this Court held that if different spices are mixed in certain proportion and they are powdered, then the original property of the particular ingredient is lost and is mixed with the properties of the other ingredients with the result that a new and a different article having a distinct name, character or use emerges. Such masalas would be covered by Tariff Item 68. Thus, the ratio laid down in this case fully applies to the facts of instant petitions, as the ratio was laid down on the facts that different spices were mixed in certain proportion and they were powdered and as a result of the same different commodities came into existence known as Garam Masala, Dal Masala, Ghana Masala etc.
Allahabad High Court Cites 19 - Cited by 9 - Full Document

Union Of India vs Delhi Cloth & General Mills on 12 October, 1962

22. Learned senior counsel for petitioners, giving references of various decisions of apex court particularly in the case of Union of India v. Delhi Cloth & General Mills Co. Ltd., A.I.R. 1963 SC 791 and Dy. Commissioner Sales Tax (Law) v. Pio Food Packers, 1980 (6) E.L.T. 343 contended that the word 'manufacture' used as a verb is generally understood to mean as 'bringing into existence a new substance' and does not mean merely 'to produce some change in a substance' however minor its consequential change may be. It is submitted that this distinction is well brought about in a passage quoted in Permanent Edition of Words and Phrases from an American Judgment : The Passage runs thus :
Supreme Court of India Cites 3 - Cited by 479 - K C Gupta - Full Document
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