DEBI PROSAD PAL, J.

( 1 ) THE petitioner in this application has challenged the order of the Additional Commissioner, Commercial Taxes, on the short question as to whether conversion of turmeric and black pepper purchased by the petitioner and crushed into powder can be considered as "manufactured or processed by him" so as to attract liability under the West Bengal Sales Tax Act, 1954 (hereinafter referred to as the Act ). The facts which have given rise to this controversy are shortly as follows : The petitioner's business is to purchase "whole" turmeric and black pepper from the market, to crush them into powder and to sell such powdered turmeric and black pepper. The petitioner purchased between 30th July, 1963 and 15th November, 1963,, "whole" turmeric and "whole" black pepper in the State of West Bengal and paid tax on the said purchase under the Act. He filed his return for the period of assessment between 30th July, 1963, to 15th November, 1963 (Dewali year 2020), showing his gross turnover for the period at Rs. 29,461. 48. As the entire sale consisted of powdered turmeric and powdered black pepper, the petitioner claimed exemption in respect of the tax on such sale as he

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