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TMI Blog2017 (1) TMI 627X X X X Extracts X X X X X X X X Extracts X X X X ..... of India and Others vs. J.G. Glass Industries Ltd. & Others [1997 (12) TMI 110 - SUPREME COURT OF INDIA]concluded that the processes adopted by the Respondent Assessee to obtain front guard, luggage, carrier, rear gear etc. were manufacturing processes. This concurrent finding of fact is not shown to be perverse. - Decided in favour of assessee - INCOME TAX APPEAL NO.709 OF 2014, INCOME TAX APPEA ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... considering the assessee's business activity as manufacturing instead of assembling Luggage carriers, Wheel Caps etc.? . 3. The Respondent Assessee is engaged in the business of manufacturing and trading of various auto accessories/spare parts/ components/tools and equipments/decorative items. The Respondent Assessee claims to manufacture front guard, luggage carrier, rear guard, side gua ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cking etc. resulting in various automobile accessories/parts. On the aforesaid examination, the CIT(A) held that the process conducted by the Respondent Assessee on the raw materials resulted in a change in the name, character and use of the raw materials. Further, the CIT(A) placed reliance upon the decision of the Apex Court in Union of India and Others vs. J.G. Glass Industries Ltd. Others (1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Respondent-Assessee is not a manufacturing process. In support he relies upon the decision of the Supreme Court in Indian Hotels Co. Ltd. vs. I.T.O. 245 ITR 538 where processing of foodstuff in a hotel was not considered to be a manufacturing activity. 8. The decision of the Apex Court in Indian Hotels Co. Ltd. (supra) is completely on different facts, i.e. processing of raw materials such as ..... X X X X Extracts X X X X X X X X Extracts X X X X
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