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Chowgule & Co. Pvt. Ltd. & Anr vs Union Of India & Others(And Vice Versa) on 25 November, 1980

In the aforesaid regard it is observed that the answer to this question depends upon what is the true meaning and connotation of the word "processing" while dealing the matter in regard to sec.8(3)(b) and Rule 13 of Central Sales Tax Rules, 1956 and Central Sales Tax Act, 1957 and the Apex Court in Chowgule's case had went on to hold that as per the websters' Dictionary the meaning of the word "process", is subject to some special process or treatment, to subject (especially raw material) to a process of manufacture, development or preparation for the market etc., to convert into marketable Signature Not Verified Signed by: ASHISH PAWAR Signing time: 19-05-2025 12:20:29 NEUTRAL CITATION NO. 2025:MPHC-GWL:8598 12 WP-11988-2022 form as live stock by slaughtering, grain by milling, cotton by spinning, milk by pasteurizing fruits and vegetables by sorting and repacking. Thus, where any commodity is subjected to a process or treatment with a view to its "development or preparation for the market", it would amount to processing of the commodity. The nature and extent of processing may vary from case to case; but with each process suffered, the commodity would experience a change. 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. Thus, 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. Here, in the present case, two different compositions are blended together to produce oil of the requisite chemical and physical composition and as a result of this blending, the quantities of oil mixed together experience change in their respective compositions, because what is produced by such blending is oil of a different composition and when the chemical and physical composition of each kind of oil which goes into the blending is changed, there can be no doubt that the operation of blending would amount to 'processing'. Thus, in the very unit of the petitioner it can be said that after processing of the blended edible vegetable oil, it is packed and the said unit cannot be any way said to engaged only in repacking of the oil.
Supreme Court of India Cites 10 - Cited by 98 - P N Bhagwati - Full Document

Sri Om Prakas Gupta vs Commissioner Of Commercial Taxes And ... on 17 May, 1965

NEUTRAL CITATION NO. 2025:MPHC-GWL:8598 10 WP-11988-2022 The nature and extent of processing may vary from case to case; in one case the processing may be slight and in another it may be extensive; but with each process suffered, the commodity would experience a change. 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 nature and extent of the change is not mate rial. It may be that camphor powder may just be compressed into camphor cubes by application of mechanical force or pressure without addition or admixture of any other material and yet the operation may amount to processing of camphor powder as held by the Calcutta High Court in Om Parkash Gupta v. Commissioner of Commercial Taxes, 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. Here, in the present case, diverse quantities of ore possessing different chemical and physical compositions are blended together to produce ore of the requisite chemical and physical composition demanded by the foreign purchaser and obviously as a result of this blending, the quantities of ore mixed together in the course of loading through the Mechanical Ore Handling Plant experience change in their respective chemical and physical compositions, because what is produced by such blending is ore of a different chemical and physical composition. 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 sec. 8(3) (b) and Rule 13. It is no doubt true that the blending of ore of diverse physical and chemical compositions is carried out by the simple act of physically mixing different quantities of such ore on the conveyor belt of the Mechanical Ore Handling Plant. But to our mind it is immaterial as to how the blending is done and what process is utilised for the purpose of blending. What is material to consider is whether the different quantities of ore which are blended together in the course of loading through the Mechanical Ore Handling Plant undergo any change in their physical and chemical composition as a result of blending and so far as this aspect of the question is concerned, it is impossible to argue that they do not suffer any change in their respective chemical and physical compositions.
Calcutta High Court Cites 8 - Cited by 29 - Full Document
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