Honble CHOPRA, J. — This appeal is directed against the judgment of the learned single Judge dated April 4, 1995 passed in S.B. Civil Writ Petition No. 2139 of 1991, whereby the learned single Judge has dismissed the writ petition filed by the petitioner-appellant holding that retreading of tyres is not a manufacturing process and therefore, the decision of respondent No.2 i.e. the District Level Screening Committee, Bhilwara not to issue the eligibility certificate in favour of the petitioner- appellant under the Rajasthan Sales Tax Incentive Scheme, 1987 (for short the Scheme) is perfectly valid. The reversion of the decision taken by respondent No.2 does not violate the principles of natural justice. (2). The facts necessary to be noticed for the disposal of this appeal briefly stated are : that the petitioner-appellant is a registered partnership firm and it carries on the business of retreading of tyres. According to the petitioner-appellant, retreading of tyres amounts to manufacturing process as defined in s.2 (k) of the Rajasthan Sales Tax Act, 1954 and, therefore, the petitioner-appellant is entitled to avail the benefit under the Scheme of 1987. (3). The case of the petitioner-appellant is that as per the Scheme of 1987, it applied for grant of eligibility certificate and that application was processed and ultimately, the respondent No.2 in its 7th meeting held on March 14, 1989 held that the petitioner- appellant is entitled to the issuance of eligibility certificate. When these proceedings were put up for confirmation before the respondent No.2 in its 8th meeting held on June 21, 1989, although the minutes of the meeting were confirmed but it was held that the recommendations regarding grant of eligibility certificate in favour of the petitioner-appellant are against the decision of their lordships of the Supreme Court and, therefore, such a certificate cannot be granted to such dealers dealing in retreading of tyres. Thus, the earlier decision taken by respondent No.2 in its 7th meeting held on March 14, 1989 was reviewed vide Minutes Annexure-5 dated June 21, 1989. (4). Aggrieved against the decision taken by respondent No.2 in its 8th meeting held on June 21, 1989 reviewing its earlier decision taken in its 6th meeting held on March 14, 1989, the petitioner appellant and two others filed writ petition before this Court on the ground that it is against the principles of natural justice. (4). Aggrieved against the decision taken by respondent No.2 in its 8th meeting held on June 21, 1989 reviewing its earlier decision taken in its 6th meeting held on March 14, 1989, the petitioner appellant and two others filed writ petition before this Court on the ground that it is against the principles of natural justice. According to the petitioner-appellant, the process of retreading of tyres amounts to manufacturing process and, therefore, the petitioner-appellant is entitled to the grant of eligibility certificate. (5). After hearing both the parties, both these contentions were repelled by the learned single Judge and the writ petition filed by the petitioner-appellant has been dismissed. Hence this appeal. (6). We have heard Mr. Vineet Kothari, the learned counsel appearing for the petitioner appellant and Mr. B.C. Mehta, the learned counsel for the respondents and have carefully gone through the record of the case. (7). Mr. Vineet Kothari, the learned counsel appearing for the petitioner appellant has drawn our attention to the definition of the word Manufacture given in s.2(k) of the Act, which reads as under : — "S.2 (k). "Manufacture" includes any process or manner of producing, collecting, extracting, preparing or making any goods; but does not include such manufactures or manufacturing processes as may be notified by the State Govt." It has been contended by Mr. Kothari that retreading of old tyres involves number of processes and the retreaded product becomes much different from its earlier product and, therefore, retreading of old tyres falls within the definition of manufac-turing process and so, the learned single Judge was wrong in holding that retreading of old tyres is not a manufacturing process. He has submitted that even if it is held that technically speaking, the retreading of old tyres does not fall within the definition of manufacture then too, the retreading of old tyres undergoes number of processes and therefore, when processes are involved in preparing a particular product, that is covered by s. 2 (k) of the Act and so, the petitioner-appellant is entitled to get the eligibility certificate. (8). It has also been contended by Mr. Kothari that the review of the earlier decision taken by respondent No.2 in its 7th meeting held on March 14, 1989 was not provided by law and so, this review being against the principles of natural justice cannot be sustained and it deserves to be" quashed. (9). (8). It has also been contended by Mr. Kothari that the review of the earlier decision taken by respondent No.2 in its 7th meeting held on March 14, 1989 was not provided by law and so, this review being against the principles of natural justice cannot be sustained and it deserves to be" quashed. (9). We have given our most earnest consideration to the rival submissions made at the Bar. (10). As per s. 2(k) of the Act, the word manufacture includes any process or manner of producing, collecting, extracting, preparing or making any goods. The processing may be with a view to develop a particular thing for preparation for the market but it does not mean that will result in manufacturing of a new commodity. If a commodity undergoes a change as a result of some operations performed on it, such operations would amount to processing of the commodity. In support of this contention, Mr. Kothari has drew our attention to a decision of the Delhi High Court in Addl. C.I.T. vs. Kalsi Tyre P. Ltd. (1), wherein while discussing the terms Manufacture and Processing of Goods, the Delhi High Court has held that the business of retreading of tyres amounts to processing of goods because the machinery used for retreading is the same as used for manufacture of new tyres. Various processes employed such as inspection, buffing, building and retreading also leads to production of new commercial article giving new lease of life to worn out tyres. Thus, what has been held by the Delhi High Court is that the activity of retreading of tyres amounts to processing of goods. It has not been held by the Delhi High Court that retreading of tyres amounts to manufacture, of a new commodity. (11). Our attention was next drawn to a decision of this Court in A.C.T.O. vs. Girrota Silica Udyog (2). In that case, the respondents excavated mineral, namely, silica-sand from mines and the minerals so excavated were crushed into pieces and after screening and grading, they were sold to various industries. The respondents claimed exemption in terms of notification dated March 23, 1963 as a manufacturer on his sales of goods to registered dealers against declarations in form ST 17 was allowed by the Tribunal. The respondents claimed exemption in terms of notification dated March 23, 1963 as a manufacturer on his sales of goods to registered dealers against declarations in form ST 17 was allowed by the Tribunal. On revision petitions by the Department, it was held by the High Court that the Tribunal had recorded a finding that the mineral excavated in lumps was not a tradable commodity. The respondents had rightly been considered to be manufactures and given the benefit of notification dated March 23, 1963. (12). Mr. Kothari next drew our attention to a decision of their lordships of the Supreme Court in Mangalore Chemicals & Fertilizers Ltd. vs. Deputy Commissioner of Commercial Taxes (3) , wherein their lordships of the Supreme Court have observed that the choice between a strict and a liberal construction arises only in case of doubt in regard to the intention of the Legislature manifest on the statutory language/Indeed, the need to resort to any interpretative process arises only where the meaning is not manifest on the plain words of the statute. If the words are plain and clear and directly convey the meaning, there is no need for any interpretation. (13). It has been contended by Mr. Kothari that the words that are used in s. 2(k) of the Act are plain and simple. The definition of word manufacture includes any process or manner of producing, collecting, extracting, preparing or making any goods and, therefore, neither any liberal nor any strict interpretation is required. These words used in s.2(k) of the Act have to be given plain meaning. He has, therefore, contended that the contention of Mr. Mehta that in fiscal matters, strict interpretation should be given has no legs to stand. (14). The next contention of Mr. Kothari is that earlier, the respondent No.2 has taken a decision in its 7th meeting held on March 14, 1989 after consultation with the Law Department of the Govt. of Rajasthan that the petitioner-appellant is entitled to the grant of eligibility certificate but later on, that decision was reviewed by respondent No.2 in its 8th meeting held on June 321, 1989 and while reviewing that decision, the principles of natural justice were not followed. He has further contended that respondent No.2 was not authorised to review its earlier decision. (15). He has further contended that respondent No.2 was not authorised to review its earlier decision. (15). To decide the controversy involved in this case, it will be very useful to quote the aims of the Scheme of 1987: INCENTIVE SCHEME No. F.4(35)FD/Gr. IV/87 Jaipur Dated 23.05.1987 (as amended by notification dt. 29.7.87 and 5.2.88) In exercise of the powers conferred by sub-s. (2) of s. 4 of the Rajasthan Sales Tax Act, 1954 (Rajasthan Act 29 of 1954), the State Govt. being satisfied that it is expedient in the public interest so to do; hereby notifies the "Sales Tax Incentive Scheme for Industries, 1987" (hereinafter referred to as the "Incentive Scheme") and exempts the industrial units from payment of tax on the sales of the goods manufactured by them within the State; in the manner and to the extent and for the period as covered by this notification." (16). Thus, it is clear that the main object of this Scheme was to exempt the industrial units from payment of tax on the sales of the goods manufactured by them within the State. (17). Now, (keeping in view the aforesaid aims and objects of the Scheme of 1987, we would like to examine as to whether the retreading of old tyres falls within the definition of manufacturing process or not? (18). In this respect, the learned single Judge has placed reliance on a decision of their lordships of the Supreme Court in P.C. Cheriyan vs. Barfi Devi (4), wherein their lordships of the Supreme Court have observed that the broad test for determining whether a process is a manufacturing process is whether it brings out a complete transformation from the old components so as to produce a commercially different article or commodity. The retreading of old tyres does not bring into being a commercially distinct or different entity. The old tyre retains its original character or identify as a tyre. Retreading does not completely transform it into another commercial article, although it improres its performance and serviceability as a tyre. Retreading of old tyres is just like resoling of old shoes. No new or distinct article emerges from retreading of old tyres. The old tyre retains its basic structure and identity. Thus, as per their lordships of the Supreme Court, every process is not a manufacturing process. Retreading of old tyres is just like resoling of old shoes. No new or distinct article emerges from retreading of old tyres. The old tyre retains its basic structure and identity. Thus, as per their lordships of the Supreme Court, every process is not a manufacturing process. Only that process is a manufacturing process, which brings out a complete transformation of the old component so as to produce the commercial article or commodity. In our considered opinion, this case is on all fours sofar as the controversy involved in this case is concerned. (19). The meaning of the expression "Manufacture" was considered by their lordships of the Supreme Court in Deputy Commissioner of Sales Tax. vs. Pio Food Packers (5), and in that decision, the test evolved for determining whether manufacture can be said to have taken place is, whether the commodity which is subjected to the process of manufacture can no longer be regarded as the original commodity but is recognised in the trade as a new and distinct commodity. The word production or produce when used in juxtaposition with the word manufacture takes in bringing into existence new goods by a process which may or may not amount to manufacture. It also takes in all the by-products intermediate products and residual products which emerge in the course of manufacture of goods. (20). In Union of India vs. Delhi Cloth and General Mills Co. Ltd. (6), their lordships of the Supreme Court have observed as under : — "Manufacture" implies a change, but every change is not manufacture and yet every change of an article is the result of treatment, labour and manipulation. But something more is necessary and there must be transformation, a new and different article must emerge having a distinctive name, character, or use. The word manufacture is used as a verb and is generally understood to mean to bring into existence a new substance and does not mean merely to produce some change in a substance however minor in consequence the change may be." (21). In B. Dar Laboratories vs. State of Gujarat (7). The word manufacture is used as a verb and is generally understood to mean to bring into existence a new substance and does not mean merely to produce some change in a substance however minor in consequence the change may be." (21). In B. Dar Laboratories vs. State of Gujarat (7). , a Division Bench of the Gujarat High Court has held as under: "When a process is adopted for convenience of sale or making the article more acceptable to the customers, if the article in question retains its essential character, it has to be taxed as such article only and the processing will make no difference. The physical state or even the composition may change but so long as the essential character of the article continues to remain the same, it has to be taxed as that commodity alone." (22). In Union of India vs. Delhi Cloth and General Mills case (supra), in para 14 of the judgment, their lordships of the Supreme Court have also observed as under : — "The word manufacture used as a verb is generally understood to mean as "bringing into existence a new substance and does not mean merely to produce some change in a substance, however minor in consequence the change may be. This distinction is well brought about in a passage thus quoted in Permanent Edition of Words and Phrases, Vol.26 from an American Judgment. The passage runs thus: — "Manufacture" implies a change but every change is not manufacture and yet every change of an article is the result of treatment, labour and manipulation. But something more is necessary and there must be transformation; a new and different article must emerge having a distinctive name, character or use." In P.C. Cheriyans case (supra), Federal Commissioner of Texation vs. Jack Zinader Proprietary Ltd. (8). , was also cited and that has been distinguished and it has been categorically held that the retreading of old tyres does not bring into being a commercially distinct or different entity and therefore, it cannot be called a manufacturing process. Their lordships have also a sound at a note of caution that definitions off manufacture given in other enactments such as, in the Factories Act or the Excise Act should not be blindly applied while interpreting the expression manufacturing purposes in s. 106 of the Transfer of Property Act. (23). Mr. Their lordships have also a sound at a note of caution that definitions off manufacture given in other enactments such as, in the Factories Act or the Excise Act should not be blindly applied while interpreting the expression manufacturing purposes in s. 106 of the Transfer of Property Act. (23). Mr. Vineet Kothari, the learned counsel appearing for the petitioner appellant has tried to distinguish P.C.Cheriyans case (supra) on the ground that that was a case under s. 106 of the Transfer of Property Act, where the premises were let out and it was claimed that they have been let out for manufacturing purposes but since, these premises were used for retreading of tyres, which is not a manufacturing process and, therefore, the lease could be terminated. It may be that at particular case has some relation with a particular enactment but the ratio of decision is of general application, and is on all fours sofar as the controversy involved in this case is concerned. (24). In Addl. C.I.T. vs. Kalsi Tyre P. Ltd.s case (supra), the Delhi High Court was concerned not only with the manufacture but with the processing of goods also. In the instant case, as stated above, the aims and object of the Scheme of 1987 was to exempt the industrial units from payment of tax on the sales of the goods manufactured by them within the State and, therefore, processing of goods has no relevance in this case and so, Addl. C.I.T.s case has no application to the facts of the present case. (25). Our attention was next drawn to a decision of their lordships of the Supreme Court in Commissioner of Income Tax Vs. N.C. Bhudharaja & Co. (9), wherein their lordships of the Supreme Court have held that the word production has a wider connotation than the word manufacture. While every manufacture can be characterised as production, every production need not amount to manufacture. The word production or produce when used in juxtaposition with the word manufacture takes in bringing into existence new goods by a process which may or may not amount to manufacture. It also takes in all the by-products intermediate products and residual products which emerge in the course of manufacture of goods. The word production or produce when used in juxtaposition with the word manufacture takes in bringing into existence new goods by a process which may or may not amount to manufacture. It also takes in all the by-products intermediate products and residual products which emerge in the course of manufacture of goods. It has been further observed that the expression manufacture and produce are normally associated with movable articles and goods, big and small but they are never employed to denote construction activity of the nature involved in construction of a dam or a building. (26). Mr. Kothari next drew our attention to a decision of their lordships of the Supreme Court in Deputy Commissioner of Sales Tax vs. Coco Fibres, wherein it has been held that where green coconut husk is soaked in saltish sea water for days together and after decomposition, it is subjected to beating by mechanical or manual process, the coconut fiber produced in the process is a distinct commodity known in commercial parlance. No one in the market would sell or supply coconut husk when coconut fibre is asked for. This authority has no application to the facts of the present case because in that case, a different commodity was brought out by certain processes. (27). As stated above, retreading of old tyres does not bring into being a commercially distinct or different entity. The old tyre retains its original character, or identity as a tyre. Retreading does not completely transform it into another commercial article, although it improves its performance and serviceability as a tyre. The old tyre retains its basic structure and identity and, therefore, retreading of old tyres does not fall within the definition of manufacture. In this view of the matter, the dictum laid down by their lordships of the Supreme Court in P.C. Cheriyans case (supra) holds the field. Thus, we entirely agree with the view taken by the learned single Judge that the petitioner- appellant was not at all entitled to the grant of eligibility certificate under the Scheme of 1987 because the retreading of tyres does not fall within the definition of manufacture. (28). It was next contended by Mr. Thus, we entirely agree with the view taken by the learned single Judge that the petitioner- appellant was not at all entitled to the grant of eligibility certificate under the Scheme of 1987 because the retreading of tyres does not fall within the definition of manufacture. (28). It was next contended by Mr. Kothari that in this case, while reviewing the earlier decision taken by respondent No.2 in its 7th meeting held on March 14, 1987 vide its 8th meeting held on June 21, 1989, the principles of natural justice have not been followed. We are not inclined to accept this contention. Clause 7 (d) of the Scheme of 1987 lays down that the benefit of the Incentive Scheme shall be available from the date of issue of the eligibility certificate. Clause 9(c) of the Scheme of 1987 provides that the Screening Committee shall be empowered to amend, suspend, restore or cancel the sanction for eligibility certificate accorded by it and copies of such orders shall be endorsed to the assessing authority. Clause 10 provides that the Incentive Scheme is in the nature of a concession and it shall not confer any right to any industrial unit/entrepreneur to claim benefit provided for under it. Thus, it is clear that the benefit of the Scheme of 1987 has been made available only from the date of issuance of the eligibility certificate. Before the issuance of the eligibility certificate, the matter is to be put up before the Screening Committee and after examining it, if it deems proper, it may recommend the sanction for grant of eligibility certificate to the assessing authority and it is the concerned assessing authority, which grants the eligibility certificate and the concerning assessing authority is required to issue the eligibility certificate in form-B within a period of 7 days from the date of the receipt of the sanction. It does not mean that if any proposal has been approved by the Screening Committee, it ipsofacto amounts to the issuance of the eligibility certificate. The right to get the benefit under the Scheme accrues only from the date the eligibility certificate is issued by the concerned assessing authority. As stated above, in this case, no such eligibility certificate has ever been issued in favour of the petitioner-appellant by the respondents. The right to get the benefit under the Scheme accrues only from the date the eligibility certificate is issued by the concerned assessing authority. As stated above, in this case, no such eligibility certificate has ever been issued in favour of the petitioner-appellant by the respondents. In this case, after the receipt of the application of the petitioner-appellant for grant of eligibility certificate, the matter was placed before the Screening Committee and the concerned Screening Committee in its 7th meeting held on March 14, 1989 approved the said proposal but when this proposal was put up for confirmation before the concerned Screening Committee in its 8th meeting held on June 21, 1989, the Screening Committee felt that its recommendation regarding grant of eligibility certificate is against the decision of their lordships of the Supreme Court in P.C. Cheriyans case (supra) and therefore, it reviewed its earlier decision. To review or amend or suspend or restore or cancel its sanction for eligibility certificate, the concerned Screening Committee had power to do so as per clause 9(c) of the Scheme of 1987. In this view of the matter, we are firmly of the view that the principles of natural justice have not been violated in this case. The respondent No.2 had authority to cancel, review or amend its sanction. (29). For the reasons stated hereinabove, we are firmly of the view that the decision of the learned single Judge cannot be held to be perverse or unjust. The learned single Judge has taken a correct view in the matter. (30). In the result, we find no force in this appeal and it is hereby dismissed with no order as to costs.