YASHWANT VARMA,J. - (1.) Heard Shri Piyush Agrawal, learned counsel for the revisionist and Shri B.K. Pandey, learned standing counsel for the Department.
(2.) The sole issue, which arises for consideration in these revisions is whether the revisionist can be said to be engaged in the "manufacture" of a taxable commodity.
(3.) The revisionist admittedly purchases cold drink concentrate and thereafter dilutes the same by adding water and infusing gas to confer effervescent qualities to the ultimate product which is then sold to the consumers through its vending machines. The case of the revisionist was that the process of dilution does not amount to "facture" as envisaged under the 1948 Act.;