2015 (10) TMI 1060

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..... Appeal of the Revenue challenges the order passed by the Income Tax Appellate Tribunal, Bench at Mumbai dated 2nd January, 2013. The assessment year in question if 2004-05. 2) The Assessee before the Tribunal and before us is a firm engaged in the business of manufacturing galvanied steel tapes and cold rolled strips. A return of income for the assessment year 200405 was filed declaring total inc .....

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..... sed by Bharat Sanchar Nigam Limited, Department of Defence, Indian Railways etc. Thus, the Tribunal seems to have had a doubt whether this process amounts to manufacture, however, in the light of the authoritative pronouncement of this Court and in the case of the very Assessee that the deduction under section 80IB of the Income Tax Act, 1961 was granted. The Tribunal's earlier order has been .....

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..... apes are classified under different heads. Moreover, upon the evidence before it, the Tribunal has noted that the uses of the final product are distinct in respect of various industries. On this basis the Tribunal has entered two fold findings. Firstly, the raw material and end products have a different commercial connotation and use. A new and distinct product emerges during the course of the man .....

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