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TMI Blog1990 (10) TMI 341X X X X Extracts X X X X X X X X Extracts X X X X ..... metal jelly obtained by conversion of the bigger stone boulders into smaller stones of varying sizes would be subjected to purchase tax under section 7-A of the Tamil Nadu General Sales Tax Act or not. The assessee-respondent was subjected to such a tax, on a reading in section 7-A of the Act that the process under which the bigger stone boulders were converted into smaller stones of varying siz ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er an activity is or is not a manufacture, or whether a process or operation is or is not manufacturing, one of the important factors is the extent of the change that has been effected in the original material, since, while every change in an article is the result of treatment, labour and manipulation, every change is not manufacture; something more is necessary, and the application of labour must ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Act. This Court affirmed the Tribunal's view saying that with regard to the purchase of the raw bones and the end-products which were sold locally, the Tribunal was right in holding that section 7-A(1)(a) of the Act was not attracted, as there had been no consumption of the goods purchased in the manufacture of other goods. 3.. Section 7-A(1)(a) of the Act uses the words: "7-A(1). Every deale ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nover for a year is less than one lakh rupees." It is not the case of the State that there was any sale of the blue metal jelly to any person beyond the State or any despatch outside the State. We are of the opinion that the Tribunal has correctly understood the law and rightly held that all the ingredients of section 7-A are not satisfied in the case of blue metal jelly obtained in the process ..... X X X X Extracts X X X X X X X X Extracts X X X X
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