TMI Blog2014 (9) TMI 724X X X X Extracts X X X X X X X X Extracts X X X X ..... activity amounts to manufacture and the assessee is eligible for claim of deduction – Decided against revenue. - Income Tax Appeal Nos. 509/2014, 510/2014 & 515/2014 - - - Dated:- 12-9-2014 - Sanjiv Khanna And V. Kameswar Rao,JJ. For the Appellant Through Mr. Kamal Sawhney, Sr. Standing Counsel. For the Respondent : Nemo ORDER Sanjiv Khanna, J. (Oral): CM No. 13629/2014 in ITA No. 510/2014 CM No. 13862/2014 in ITA No. 515/2014 Exemption applications are allowed, subject to all just exceptions. INCOME TAX APPEAL NOS. 509/2014, 510/2014 515/2014 These appeals by the Revenue pertain to Assessment Years 2006-07, 2008-09 and 2009-10. The common issue raised is whether the respondent-assessee was engaged i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lters like synthetic pre filters, secondary filters, activated carbon filters, HEPA (High efficiency particulate arrestor) filets in various permutations and combinations. The combinations depend upon the need of the customer and the area of application. This is probably for the first time in India that an array of technologies for air purification, which were available, has been combined into a single system for the highest efficiency. Apart from this in order to make the system user friendly we have incorporated programmable timers in the system so that the user can pre define the time of switching on and off and the time of running of the system. The system has been appreciated and well accepted by the health care industry workers. We ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as entirely different from its constituents or parts. The product manufactured or produced, i.e. the air purifier or air purification system, was completely a new and an entirely different commodity having distinct name, character and use. The respondent-assessee had even filed photographs before the Assessing Officer to support his contentions on the manufacturing activities undertaken. The respondent-assessee had filed a flow chart of the manufacturing process. The manufacturing unit stood registered with District Industries Centre, Roorkee, Pollution Control Department, Commercial Tax Department, Uttaranchal, etc. 5. The Assessing Officer did not dispute or question the purchases of the parts used for manufacturing as well as the sale ..... X X X X Extracts X X X X X X X X Extracts X X X X
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