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TMI Blog2002 (6) TMI 26X X X X Extracts X X X X X X X X Extracts X X X X ..... instance of the Revenue, the following questions are referred for our opinion for the relevant assessment years as mentioned at the outset: Assessment years 1981-82, 1982-83 and 1983-84: "(1) Whether, on the facts and in the circumstances of the case and in law, the Tribunal was right in coming to the conclusion that the assessee-company was engaged in manufacturing and processing activities an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nkumar Gordhanbhai and Bros. (P.) Ltd.), this court decided in CIT v. Ashwinkumar Gordhanbhai and Bros. (P.) Ltd. [1995] 212 ITR 614 that the aforesaid business involves manufacturing or processing of goods and the assessee is, therefore, an industrial company. Following the aforesaid decision, our answer to the first question is in the affirmative, i.e., in favour of the assessee and against the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng unit as envisaged under section 80J(4)(iv) involves a disputed question of fact on which the Commissioner (Appeals) and the Tribunal have given concurrent findings in favour of the assessee. In view of the above discussion, our answer to the second question is also in the affirmative, i.e., in favour of the assessee and against the Revenue. The reference, accordingly, stands disposed of with ..... X X X X Extracts X X X X X X X X Extracts X X X X
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