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Issues involved: Determination of whether the appellant's activity constitutes manufacturing activity.
Summary: The appellant raised three questions of law, with the relevant question being whether the activity can be considered manufacturing since the appellant is crushing manganese ore to manganese powder. The CIT(A) held that the appellant's actions amount to manufacturing, considering the various processes involved in transforming the ore into a different product. The Tribunal, citing a previous judgment, affirmed the CIT(A)'s decision. The High Court noted that even if the activity did not strictly qualify as manufacturing, it would still amount to production. Based on the factual findings, the Court found no fault in the Tribunal's judgment and dismissed the appeal.
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