S(uiii) is tobacco uhich has itself been subjected to a manufactuingprocess. Whether, if tobacco uhich has been subjected to a manufactuing process ls agotn subjected to a further manufacturing process bg the purchaser it will fall under Section S(uii) does not aise for consideration in this case, and LUe expressno opinion of ours on that question. Factuallu the position was that uhat the assessee purchased hnd not been subiected to anu manufacturingprocess, and, there-fore, the sale o-f ttrc tobacco, no doubt knoun euen at that stage to the trade as chewina tobacco, did not bring that sale uithin the scope of Section S(uiil. It uas the sale of the manufacturedproduct elfected bu the assessee, manu.factured -from the tobacco thnt he hadpurchased. that came within the scope o-f Section S(uiil. No doubt, soakinq in -iagqery water and the process of bulking uere processes common both to the seller and to the assessee uho purchased the tobacco. In other words, the assessee subjected the tobacco he had purchased to tLrc same process. Had he stopped tuith that alone. it might be possible to contend that uhat he sold subsequentlu uas not a manufactured product. Takinq, howeuer.-the cumulatiue effect of the uarious processes to u.)hich the assessee subjected the tobacco before he sold it. it is clear that uhat was euentuallv sold bu the assessee utas a manufacturedproduct, manufactured-from the tobqpco that the assessee hadpurctmsed. Soakinq in iaaaeru Luater is not the onlAprocess to be considered. The additiart of flauourinq essences and shredding of the tobacco should establi"sh that what the assessee sold uas aproduct substantiallu different from uthat Lrc hadpurchased. Once aaain, ue haueto point out that the -fact that this assesseepurchnsed the tobacco as chewing tobaccodid not determine thequestion, uhether the sale of tLrcproducts manu.facturedbu him from out of that tobacco falls uithin thescooe of SectionS(uiilor not.
