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TMI Blog1981 (4) TMI 151X X X X Extracts X X X X X X X X Extracts X X X X ..... e assessee is a Registered Firm having a ginning factory. In computing the total income for the assessee. 1977-78 corresponding to the previous year ended 31st March, 1977 the assessee had claimed investment allowance under s. 32A in respect of a sum of Rs. 1.02.426 invested in Power Generator and Electric motor for that factory. The allowance deducted was Rs. 25,607 at the rate of 25 per cent of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed that the only question was whether the ginning of corron amounted to manufacture and in view of the decision of the Supreme Court in the case of Chandlal Kishorilial AIR 1969 SC 1073, ginning involved the transformation of raw material into a different product and must be accepted as manufacture. On the other hand, it was contended on behalf of the Revenue that the wording of s. 32A did not inc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e of Chandlal Kishorilal where it was held that to while cotton in its unsigned state contains cotton seeds, by the ginning and separating the seeds, it will not be correct to say that it remains as cotton and that two distinct commercial goods are produced in the process. It has also been held in the case of Girdharialal Munnelal (1971) 27 STC 316 (MP) that ginning by a complicated process throug ..... X X X X Extracts X X X X X X X X Extracts X X X X
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