To decide what is "manufacture" Dept should have a panel of experts

Morinda Cooperative Sugar Mills Ltd vs. CIT (Supreme Court)

The terms `manufacture’ implies a change, but every change is not a manufacture, despite the fact that every change in an article is the result of a treatment of labour and manipulation. However, this test of manufacture needs to be seen in the context of the above process. If an operation/process renders a commodity or article fit for use for which it is otherwise not fit, the operation/process falls within the meaning of the word `manufacture. Q whether conversion of sugar into sucrose is “manufacture” should be decided by experts.