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2012 (5) TMI 341 - HC - Income TaxDeduction under Section 80-I - manufacturing and trading of hosiery garments such as pullovers, mufflers and blankets etc. - labeling, tailoring, packing, pakki checking, buttons and button holes, linking etc. - AO opined that these processes did not amount to manufacturing activities or production of articles. - held that:- It is worthwhile to notice that in para 23 of the judgment of Hon'ble the Supreme Court rendered in the case of Arihant Tiles & Marbles (P) Ltd. (2009 (12) TMI 1 (SC)), Hon'ble Mr. Justice S.H. Kapadia (now Hon'ble Chief Justice of India) highlighted another aspect observing that if the view of the revenue namely that the activities undertaken by the assessee- respondent was not in the nature of 'manufacture, was to be accepted then it would have had serious revenue consequences. It was noticed by his Lordship that the assessee- respondent were paying excise duty and some of them were job workers and their activities were recognized by various government authorities as 'manufacture' - Decided in favor of assessee.
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