2008 (1) TMI 936

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..... ng this appeal the relevant question of law is (b) and the same is reproduced as under : (b) Whether on the facts and circumstances of the case and in law, the Hon'ble Tribunal was justified in holding that the assessee's activity can be considered as manufacturing activity since the assessee is only crushing the manganese ore to the manganese powder ? 2. The CIT(A) in the appeal .....

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..... R 126(Bom) as affirmed by the Supreme Court in the case CIT vs. Sesa Goa Ltd. (2004) 192 CTR (SC) 577: (2004) 271 ITR 331(SC) and confirmed the finding of the CIT(A). 4. In our opinion, considering that the expression production is of much wider amplitude than the expression manufacture and the finding of fact recorded, even if it is held that the act does not amount to manufacture it still w .....

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