Judgment :- DR. A. S. ANAND, C.J. The respondent-assessee is a manufacturer of tin containers. The assessing authority brought to tax the turnover of Rs. 19, 300 representing the purchase of tin sheets under section7-A of the Tamil Nadu General Sales Tax Act, 1959. The appeal filed by the assessee-respondent before the Appellate Assistant Commissioner questioning the correctness of the order of the assessing authority to bring the turnover of tin sheets under section7-A of the Act, failed. However, in the second appeal, the Sales Tax Appellate Tribunal (Second Additional Bench), Madras, deleted the turnover of Rs. 19, 300 and held that the said turnover could be assessed under section7-A of the Act. The Revenue is in revision before us. 2. The precise issue involved in this tax revision case is whether the tin sheets which were purchased by the assessee could be brought to tax under section7-A of the Tamil Nadu General Sales Tax Act, 1959. The answer to the question would depend upon whether the tin sheets covered by the turnover could be said to have been consumed in the manufacture of tin containers so as to attract levy of tax under section7-A of the Act. There is no dispute that if the tin sheets cannot be said to have been consumed in the manufacture of tin containers, then section7-A of the Act would not be attracted, as all other conditions stand satisfied. 3. One essential condition which is required to be fulfilled for attracting the provisions of section7-A of the Act is that the goods purchased should be consumed in the manufacture of other goods for sale or otherwise. The Appellate Assistant Commissioner noticed that tin sheets for Rs. 19, 300, charcoal for Rs. 152, lead, etc., for Rs. 7, 642 purchased from unregistered dealers were consumed in the manufacture of tin containers. All the three commodities, viz., tin sheets, charcoal and lead were actually consumed in the manufacturing process of the goods, viz., tin containers. Finding that the tin sheets were definitely not the same thing as tin containers, the Appellate Assistant Commissioner held that the assessment under section 7-A was rightly made. 4. There are several tests for determining whether a commodity is consumed in the manufacture of another commodity. Finding that the tin sheets were definitely not the same thing as tin containers, the Appellate Assistant Commissioner held that the assessment under section 7-A was rightly made. 4. There are several tests for determining whether a commodity is consumed in the manufacture of another commodity. The generally prevailing and accepted test is whether the article produced is regarded in the trade by those who deal in it as distinct in identity from the commodity involved in its manufacture. When series of changes take place and those changes take the commodity to a point where commercially it can no longer be regarded as the original commodity and is instead recognised as a new and distinct commercially identifiable article, then undoubtedly a process of manufacture can be said to have taken place during which the original commodity has been consumed in the manufacture of the new commodity. See with advantage the decisions reported in Hindustan Timber Depot v. State of Tamil Nadu 1984 (56) STC 69 (Mad.) and Deputy Commissioner of Sales Tax v. Pio Food Packers 1980 AIR(SC) 1227, 1981 ECR 47, 1980 (6) ELT 343 , 1980 (46) STC 63, 1980 (S) SCC 174, 1980 (3) SCR 1271 , 1980 TaxLR 1706, 1980 SSCC 174, 1981 UPTC 667, 1980 Suppl(SCC) 174, 1980 E(LT) 343, 1980 Supp(SCC) 174, 1980 SCC(Tax) 319 (SC). By no stretch of imagination can the tin containers be said to be same commodity as tin sheets. In the process of manufacture of tin containers from tin sheets, charcoal and lead have also been consumed, implying thereby that some amount of welding operation has also gone into. The manufacture of different sizes and designs of tin containers brings into existence commercially identifiable distinct commodities. Those commodities cannot be said to be the same as tin sheets. In commercial parlance, the two are entirely different and distinct commodities. We are fortified in our view by the decision in T.C. No. 735 of 1982 decided on August 7, 1991 [Reported as Decan Limeshell & Co. v. State of Tamil Nadu in 1992 (87) STC 29 (Mad.)] holding that lime shell and lime powder, which is manufactured by burning the lime shell, are two distinct and separate commodities, and so far as lime shell is concerned, it would attract the provisions of section7-A of the Act. 5. v. State of Tamil Nadu in 1992 (87) STC 29 (Mad.)] holding that lime shell and lime powder, which is manufactured by burning the lime shell, are two distinct and separate commodities, and so far as lime shell is concerned, it would attract the provisions of section7-A of the Act. 5. Considering this position, we are satisfied that the Tribunal fell in error by holding that section 7-A was not attracted so far as the tin sheets are concerned. The finding that the tin sheets could not be said to have been consumed in the process of manufacture of tin containers which are distinct and separate commodities, is clearly erroneous. The order of the Tribunal, under the circumstances, cannot be sustained. 6. The tax revision case accordingly succeeds and is allowed. The order of the Tribunal is set aside and that of the Appellate Assistant Commissioner and the assessing authority restored. There will be no order as to costs.