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2019 (10) TMI 1001 - HC - Income TaxDeduction u/s.10B - Manufacturing - Export of Copper Cladded Glass expoxy Laminate (CCGL) - claim denied as assessee had not carried out any manufacturing activities qua the said product i.e. CCGL - Tribunal allowed deduction - HELD THAT:- It appears that in the case on hand, the raw material is first sent to the shearing department. The shearing machine is set for the desired size and the laminates are cut into the specified sizes as required by the customer. The laminates are, thereafter, checked for the oxidation effect. A thorough surface clearing is done to remove the oxidation. The Quality Control Department, thereafter, would verify the quality parameters like the thickness of the material, thickness of copper using Alco Meter etc.. At the end of the entire process, the final product is called as CCGL. It goes without saying that the change or the series of changes brought about by the application of the process explained above, the commodity in the form of CCGL can no longer be regarded as the original commodity but is, instead, recognized as a distinct and new article that is emerged as a result of the process. We are of the view that no error, not to speak of any error of law, could be said to have been committed by the Appellate Tribunal in passing the impugned order. We would not like to disturb the order passed by the ITAT. - Decided against revenue.
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