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2015 (11) TMI 1134 - AT - Income TaxDeduction u/s 80IC - manufacturing and sale of nutritional food supplements, agro products and veterinary feed supplements, etc. - assessee is merely mixes various ingredients, required for final products, with the help of machineries and the final product/finish product is filled in pouches - Held that:- Analyzing the processing activity done by the assessee, we find that the resultant end product is commercially known differently in the trading world, therefore, certainly it can be said that the activity of the assessee amounts to manufacture, consequently, entitled to deduction u/s 80IC of the Act, because, mixing various ingredients in a specified manner and the net result come into nutritional food supplement, agro products and veterinary food supplement amounts, which is used by the public at large for different purposes and is commercially known differently, therefore, it amounts to manufacturing. The resultant end product is outcome of combination of efforts with the help of men and machine using homogenizer. Likewise, Aloevera juice is extracted from the aloevera leaves with the help of machines and men and the end product is aloevera juice, which is outcome of various processes, therefore, whole activity of the assessee routs through various processes, thus, certainly amounts to manufacturing. The case of the assessee further find support from the decision in the case of Ramit Kumar Sharma vs DIT (IT) (2009 (1) TMI 12 - AUTHORITY FOR ADVANCE RULINGS ) wherein the assessee intend to start a tractor manufacturing industry in the state of Himachal Pradesh, wherein, the primary job was to provide, milling, tooling and grinding of surface of rear cover etc, which are important part of tractor, it was held that the activities amounts to manufacture or production of an article difference from raw castings, thus, entitled to deduction u/s 80IC of the Act. As mentioned earlier in Mrs. Delna Rustom Boyce (2009 (10) TMI 23 - AUTHORITY FOR ADVANCE RULINGS) processing, packaging and packing of fruits and vegetables were held to be eligible for deduction u/s 80IB of the Act, therefore, it can be concluded that the end product is commercially known differently, therefore, the assessee is involved in manufacturing - Decided in favour of assessee.
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