TMI Blog2001 (4) TMI 10X X X X Extracts X X X X X X X X Extracts X X X X ..... tion 80J - - - - - Dated:- 27-4-2001 - Judge(s) : Y. K. SABHARWAL. and BRIJESH KUMAR. ORDER C. A. Nos. 3967-71 of 1999: At the instance of the Revenue, the following questions relating to the assessment years 1980-81 to 1984-85 were referred for the opinion of the High Court under section 256(2) of the Income-tax Act, 1961: "(1) Whether, on the facts and in the circumstances of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hese appeals, we are not concerned with the second question and in relation thereto, learned counsel for the Revenue did not make any submission. The Tribunal, while answering the aforesaid questions in favour of the assessee, has relied upon the decisions of the Kerala High Court in CIT v. Marwell Sea Foods [1987] 166 ITR 624 and CIT v. Relish Foods [1989] 180 ITR 454. The case of the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d description of the process by which prawns were prepared for export and the appellate authorities had under stood the various stages through which the prawns passed as processes involving production or manufacture. Here nothing of the kind was placed by the assessee before the taxing authorities. The present case is squarely covered by the decision in the case of Relish Foods [1999] 237 ITR 59 ( ..... X X X X Extracts X X X X X X X X Extracts X X X X
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