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2013 (12) TMI 715 - AT - Income TaxCutting and polishing of rough diamonds - Manufature or not - Additional depreciation - Held that:- Raw diamonds and cut and polished diamonds were different and distinct marketable commodities having different uses - Therefore, a company engaged in cutting and polishing raw diamonds for the purpose of export was engaged in the processing of goods to convert them into marketable form - The raw and uncut diamond is subjected to a process of cutting and polishing which yields the polished diamond, but the polished diamond is a new article or thing which is the result of manufacture or production - The cut and polished diamond could not be treated a new article or thing and that cutting and polishing of diamonds cannot be held manufacturing or production - Cutting and polishing of rough diamond in to polished diamond is not manufacturing or producing of a new article or thing - Decided against assessee.
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