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2015 (12) TMI 1704 - AT - Income TaxEntitlement to deduction u/s 80-IB - scope of manufacture - denial of claim as conversion of 24 Kt Gold into 22 Kt Gold does not amount to manufacture - Held that:- The activity for converting gold bricks, biscuits or bars, into jewellery amounts to “production or manufacture of a new article. The gold, silver or platinum in bar, biscuits or brick form, is converted by manual labour and by the use of implements/tools or by machinery, culminating into an entirely new article/thing called jewellery or ornaments. Jewellery is a wearable item and is used by both men and women. Jewellery/ornaments in common parlance or in commercial terms has a distinct identity, treated as a new article and not the same as raw or standard gold in the form of bricks, biscuits or bars. As a result of the said processing a commercially different saleable product comes into existence. Jewellery has a distinctive name, character and use. It can no longer be regarded as the original commodity, has separate consumers and is a new commercial commodity. The activity of the respondent assessee amounts to ‘manufacture or production - Decided in favour of assessee.
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