TMI Blog2004 (7) TMI 71X X X X Extracts X X X X X X X X Extracts X X X X ..... he assessee with regard to nearly all its contracts really amounted to manufacture and/or processing of goods and it involved process of manufacture/production of commercially different articles out of the raw materials." - Commissioner of Income-tax (Appeals) held that the assessee was an industrial company. - this finding of fact has been affirmed by the Tribunal that the assessee was involved i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... income from supervision and commissioning of heaters and erection of gas generation plants, furnaces and also manufactures equipment for these purposes and imparts technical know-how, for which services it received design and consultancy fees. Against the order of the Assessing Officer, rejecting the contention of the assessee, the appeal was preferred before the Commissioner of Income-tax (Appe ..... X X X X Extracts X X X X X X X X Extracts X X X X
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