1995 (4) TMI 12

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..... for the assessment year 1971-72, this court has found that the assessee's activities are : (i) sorting and grading of chillies as per the Agmark specifications and make them fit for export ; and (ii) before such export, clipping and stemming of chillies. The court, on the said basis has held that, "if this was to be held to fall within the definition of 'processing', we are afraid any small ac .....

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..... mining. " Learned counsel for the assessee, however, has brought to our notice a judgment of the Supreme Court in Empire Industries Ltd. v. Union of India [1986] 162 ITR 846. The judgment has taken into account the definition of the word "manufacture" in section 2, introduced retrospectively by the Central Excise and Salt and Additional Duties of Excise (Amendment) Act, 1980, and opined, "if a n .....

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