2000 (12) TMI 7

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..... e, engaged in cutting and polishing of diamonds, amounts to manufacturing or production of goods and is entitled to deduction under section 80-I - Held, no - Civil Appeal No. 180 of 1999 - - - Dated:- 5-12-2000 - Judge(s) : S. P. BHARUCHA., N. SANTOSH HEGDE. and Y. K. SABHARWAL. ORDER We are concerned with the assessment years 1983-84 and 1984-85 in this appeal against the order of a Di .....

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..... gs which, among other conditions, manufacture or produce any article or thing. The question, therefore, is whether the asses see, in cutting and polishing diamonds manufactures or produces any article or thing. The Tribunal took the view that it did because in "common parlance and commercial sense raw diamonds are not the same thing as polished and cut diamonds. The two are different entities in .....

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..... was an industrial company within the meaning of section 2(8) of the Finance Act, 1975, and that, in answering that question, the High Court had held that raw diamonds and cut and polished diamonds were different and distinct marketable commodities having different uses ; therefore, a company engaged in cutting and polishing raw diamonds for the purpose of export was engaged in the "processing of .....

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