Adarsh Kumar Goel, J.

1. This order will dispose of W.P. (C) No. 1683 of 2010, W.P. (C) No. 6445 of 2010 and W.P. (C) No. 1677 of 2010, as it is stated by learned counsel for the parties that the same issue is involved in all the three petitions. In W.P. (C) No. 1683 of 2012, the petitioner has challenged the order dated August 28, 2009 passed by the Commissioner of Taxes, Guwahati, under section 105 of the Assam Value Added Tax Act, 2003 holding that the process of production of soapstone powder from soapstone did not amount to manufacturing for the tax benefits under the Assam Industries (Tax Exemption for Pipeline Units) Order, 2005 and consequential order dated March 3, 2010 declining to renew certificate of entitlement.

2. The case of the petitioner is that it is producing soapstone powder from soapstone. The process followed is as follows:

Soapstone which is also known as steatite or soaprock is a metamorphic rock, a talc schist. It is largely composed of mineral talc and is rich in magnesium. It is produced by dynamothermal metamorphism and metasomatism which occurs in the areas where tectonic plates are subducted, changing rock by heat and pressure with influx of fluids b