What is Manufacture?

Manufacture [Section 2(15)]
Manufacture includes producing, making, extracting, altering, ornamenting, finishing,
or otherwise processing/treating/adapting any goods.
 Manufacture is mainly concerned with change, but every change does not
amount to manufacture.
 Manufacturing is thus, a process which leads to such a decisive change in the
original raw material that a new and different marketable article emerges,
having a distinctive name, character or use.
 Manufacture does not include mere affixing brand name, labeling, repairing,
reconditioning, grading, sorting, polishing, re-packing, etc. as no new article
emerges.
 Every manufacture involves a process, but each and every process carried on
in regard to the goods is not a manufacture. The process must be such that the
resultant goods are commercially different from the original goods.
Whether a particular activity amounts to manufacture or not depends upon the facts
of each case. There is no standard test to determine, conclusively, whether a
particular activity or process amounts to ‘manufacture’ or not. However, the following
tests can be applied, as laid down by various Courts:
(a) There should be some process on the goods.
(b) Such process may be carried out by the dealer or any third person hired by the
dealer.
(c) Such process must bring about changes in the substance of the original goods.
(d) The changes must result in the emergence of a commercially new and different
article.