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TMI Blog2014 (7) TMI 1000X X X X Extracts X X X X X X X X Extracts X X X X ..... ver Jewellery, he filed all the details by addressing various letters - That proved purchases, sales, consumption of silver in manufacturing of Diamond Studded Silver Jewellery, list of workers and that there were 10 workers in Diamond Division and 23 in Jewellery division - clarifications from the consultant, certificate from the Sales Tax Department, Daman, all this material remained uncontrover ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d erroneous inference drawn by the Tribunal as also the Commissioner of Income Tax (Appeals) from the contents of the remand report submitted by the Assessing Officer. This is a clear case where the findings are perverse and are vitiated by an error of law apparent on the face of the record. The appeal be, therefore, admitted. 3. We have with the assistance of Mr. Malhotra perused the memo of a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... peals) directed once again a remand. The remand report was submitted by the Assessing Officer on 15th October, 2007. 4. It is the contents in this remand report which Mr. Malhotra would challenge and submit that they did not contain anything to favour the case of the assessee rather the same disputes the case of the assessee. 5. We are unable to agree because after the submission of the rema ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rs in Diamond Division and 23 in Jewellery division. The clarifications from the consultant, certificate from the Sales Tax Department, Daman, all this material remained uncontroverted. The Diamond Studded Silver Jewellery, after the aforementioned activity, sold to M/s. Shukra Jewellery Ltd. was, therefore, in the given facts and circumstances termed as 'manufacture'. It is in these circu ..... X X X X Extracts X X X X X X X X Extracts X X X X
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