TMI Blog1978 (11) TMI 103X X X X Extracts X X X X X X X X Extracts X X X X ..... under s. 5(1)(xxxii) of the WT Act the value of the interest in the assets forming part of the business carried on by the partnership firm Ms. D.R. Chillal Sons. The Wealth tax Officer held that the claim is not admissible and the assessee has invested in a firm which cannot be termed as an industrial company. He was of the opinion that the Pickles and Masalas are really not manufactured but pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sing of goods" came up for consideration before the Bench of the Tribunal to which one of us, the Accountant Member, was a party in ITA No. 917/PN/76-77. The Tribunal referred to the decision of the Supreme Court in AIR 1963 page 791 wherein the Supreme Court defined the term "manufacture" to mean as follows: "Manufacture implies a change, but every change is not manufacture and yet every change ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ining. The instant case falls within the expression "manufacturing of goods". The firm in which the assessee is a partner manufactures Pickles and Spices. The product manufactured by the firm is something which is entirely different from the raw materials used and thus the manufacturing activities result into bringing into existence of something which is different from its components. Thus the ass ..... X X X X Extracts X X X X X X X X Extracts X X X X
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