Tribunal held that original products used by the assessee were wooden planks, evafoam, thermocol, adhesive tape, pneumatic, stapler pins, and nails. The final product obtained in the process by the assessee was wooden crates which were a distinct and separate article different from all the products that went into the manufacture and was recognised as a distinct product by the Central excise and value added tax classification which had assigned the product a specific code and serial number respectively in the Central excise and value added tax Schedules. In terms of the Uttrakhand Value Added tax Act, 2005, wooden crates were recognized as a distinct product and item. Similarly the assessee had been registered as manufacturer with the District Industries Centre and registered as a factory under the Factories Act. The assessee had been granted exemption from excise duty which was only granted to manufacturing units. The term as defined by section 2(29BA) would include any activity that results in the creation of an article or object that was new and distinct from the raw material that went into its manufacture and having a different name, character, use and/or integral structure. The wooden crates were completely distinct from the planks, nails, fevicol, foam etc. that were used to make them and they had a use of their own. The change brought in the wooden planks by hand by the labourers using small cutters would amount to manufacture of a product, the wooden crates, by the assessee. Further when four Departments of the Government had considered the assessee a manufacturing unit, another Department of the Government could not take a contrary view or a view inconsistent with the view taken by the other Departments of the Government. (AY. 2012 -13)