In Brief
The Court addressed whether cutting and polishing rough granite blocks into polished stones or tiles creates a distinct taxable commodity. It held that a mere conversion into polished slabs (through cutting and polishing) does not create a new commodity—these remain classified as granite stones under the tax schedule. However, if the process involves creation of actual tiles through multiple processing stages (cutting, slicing, polishing, edge-cutting, buffing), a new and commercially distinct product emerges falling under a separate tax entry. The critical distinction lies in the nature and extent of processing and the commercial identity of the end product. The Court allowed the appeals and remitted the matter to the Assessing Officer to conduct proper enquiry into the specific process and products involved before determining tax liability.
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