Judgment

Bharucha, J.-The principal judgment and order under appeal and the orders following it, also under appeal, were passed by a Division Bench of the High Court of Madhya Pradesh on writ petitions filed by the appellants.

2. Very briefly stated, the facts are these: The appellants purchase iron and steel scrap from the Bhilai Steel Plant and other parties. The scrap, in the form of defective angles, flats, channels, tubes and coils is of very considerable size. The appellants cut down the scrap so that it may be utilised by rolling mills and forging parts manufac­turers, gear and pinion manufacturers and dye block manufacturers. The question is whether such cutting down, with the help of shearing machines and glass cutting, of the scrap of widths of 2 to 5 and thickness upto 2.5" into strips of the size of 2" to 4" is a process of “manufacture” within the special definition of that word in Section 2(j) of the Madhya Pradesh General Sales Tax Act. The definition reads thus :

“2(j) “manufacture” includes any pro­cess or manner of producing col­lec­ting, extracting, preparing or making any goods and in respect of trees which have been severed from the land or which have been fel