C.I.T..Mumbai vs M/S.Emptee Poly-Yarn Pvt.Ltd

The Supreme Court clarified that the term 'manufacture' under the Income Tax Act requires a process that renders a commodity fit for its intended use, as established in the context of converting partially oriented yarn (POY) into texturized yarn through a thermo mechanical process. The Court held that POY, being a semi-finished product, does not qualify as a manufactured good until it undergoes this specific transformation, which introduces structural changes. The judgment distinguished the facts from the case of Commissioner of Central Excise, Mumbai-V vs. Swastik Rayon Processors, asserting that the latter's ruling does not apply to POY's conversion process under Section 2(F) of the Central Excise Act.