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2009 (5) TMI 588 - AT - Income TaxExemption u/s 10B - Manufacture Or Production - 100% EOU - Revision u/s 263 - Processing of goods - AO found that assessee simply carried out trading of manufactured items purchased from local traders is found perverse on facts - AO further found that no manufacturing has been undertaken by the assessee on its own and only job charges paid for the work done by other manufacturers - Held that: - findings of the AO are not correct - Assessee has purchased raw materials, semi finished goods etc. and undertaken various manufacturing activities - The activity carried out by the appellant thus was not that of giving mere feather touches. Even though the original material did not lose its identity completely yet a different commercial commodity has been brought into existence by the appellant, the end-product so produced being different and distinct both in character and use as well. Appellant's registration with various Government agencies as a manufacturing unit and the findings of fact as are reached, we hold that the appellant could be said to have undertaken business activity amounting to manufacture or production of articles in these years under appeal before us and the income thereof is thus eligible for exemption under s. 10B of the Act.
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