Can ITC be claimed in this scenario?

Dear all:

One of my relatives is doing rice business, he purchases paddy from farmer without paying any tax (as tax is not applicable for paddy). Later, for converting paddy into rice, he goes to mill where they charge 5 percent tax for the conversion process. Finally, he sells rice to his customers without any tax (as tax is not applicable for non-branded rice) His question is, since he pays tax for conversion process, can ITC be claimed for the amount paid as tax and apply for refund of that amount? Please advise.