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Issues:
- Whether the assessee was entitled to exemption under section 5(1)(xxxii) of the Wealth-tax Act, 1957 for the assessment years 1973-74 and 1974-75. - Whether the firm, Prakash Enterprise, could be treated as an industrial undertaking despite engaging in printing on cotton cloth on a job basis. Analysis: For the assessment years 1973-74 and 1974-75, the individual assessee, a partner in two firms engaged in the business of dyeing and printing of cotton cloth, claimed exemption under section 5(1)(xxxii) of the Wealth-tax Act, 1957. The Wealth-tax Officer initially denied the exemption, including the value of the assessee's interest in the firms' assets, arguing that Prakash Enterprise got printing done on a job basis. However, the Appellate Assistant Commissioner recognized Prakash Enterprise as an industrial undertaking and granted the exemption. The exemption claim for the other firm was not discussed. The Revenue appealed to the Appellate Tribunal, where the assessee argued that both firms' businesses were similar to another partner's firm, which was deemed an industrial undertaking. The Tribunal found that Prakash Enterprise engaged in processing goods, purchased raw materials, and was involved in the processing of goods, rejecting the Wealth-tax Officer's view. The Tribunal concluded that both firms qualified as industrial undertakings under the Act. The central issue revolved around whether the business activities of printing and dyeing constituted manufacturing or processing of goods as per the Explanation to clause (xxxi) of section 5(1) of the Wealth-tax Act, 1957. Referring to a previous case, the court affirmed that printing and dyeing involved various processes like bleaching, dyeing, printing, and calendering, which amounted to manufacturing or processing of goods. Consequently, the court upheld the Tribunal's decision that both firms were industrial undertakings within the Act's definition. As a result, the court answered the first question in the affirmative, ruling against the Revenue. Since the first question was decided in favor of the assessee, the court did not address the second question. The case was remanded to the Appellate Tribunal for further action in line with the court's decision, with no cost orders issued.
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