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2010 (1) TMI 18 - SC - Income TaxManufacture – Meaning of – what to consider – dictionary meaning or process - whether twisting and texturising of POY amounts to 'manufacture' – held that - Repeatedly this Court has recommended to the Department, be it under Excise Act, Customs Act or the Income Tax Act, to examine the process applicable to the product in question and not to go only by dictionary meanings. This recommendation is not being followed over the years - The term "manufacture" implies a change, but, every change is not a manufacture - However, this test of manufacture needs to be seen in the context of the above process. If an operation/process renders a commodity or article fit for use for which it is otherwise not fit, the operation/process fall6 s within the meaning of the word "manufacture - POY is a semi-finished product. It is a raw material/input. That raw material or input gets converted into a texturised yarn by reason of the thermo mechanical process. POY is unfit for manufacture of fabric – held as amount to manufacture
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