2011 (7) TMI 186

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..... pretation that they were not purchased for testing when in fact they were so purchased for testing - find that the judgment of the Tribunal does not consider the question whether the products were purchased for testing and, therefore, whether the activity of the assessee of using that products in the machine amounts to manufacture and whether the relevant year can be considered to be initial Asses .....

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..... reted to mean the manufacture or production for the purpose of commerce and not for the purpose of testing. According to the learned Counsel, the Tribunal has not properly appreciated this issue and has passed its conclusion on irrelevant material such as admission of the appellant that the appellant had resold the products and paid sales tax on it. In the submission of the learned Counsel for the .....

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