M/S M.J. Timber Merchant & Comm. Agent vs State Of U.P & Ors

The Supreme Court reversed the Allahabad High Court's decision in Civil Misc. Writ Petition No. 1419 of 2004, which upheld a Commissioner's circular regarding tax liability under Section 2(ee) of the Uttar Pradesh Tax Act. The Court held that the circular improperly created tax liability by broadly categorizing purchases from unregistered dealers as manufacturing activities without factual determination. The Court emphasized that the definition of 'manufacturer' requires a factual basis for determining manufacturing activities, thus invalidating the circular's implications on tax liability.