TMI Blog1987 (2) TMI 49X X X X Extracts X X X X X X X X Extracts X X X X ..... under section 271(1) of the Wealth-tax Act, 1957: " Whether, on the facts and in the circumstances of the case, the Tribunal was correct in holding that the firm in which the assessee was partner was an industrial undertaking within the meaning of the Explanation to section 5(1)(xxxi) of the Wealth-tax Act, 1957, and was entitled to exemption under section 5(1)(xxxii) of the Wealth-tax Act, 1957 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was entitled to the exemption claimed. The Wealth-tax Officer did not accept the claim for exemption made by the assessee. Aggrieved, the assessee filed two appeals before the Appellate Assistant Commissioner for both the years. The appeals were dismissed by the Appellate Assistant Commissioner. The assessee, thereafter, went up in second appeal to the Income-tax Appellate Tribunal. The Income- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er, was engaged in an industrial undertaking as defined in the Explanation to section 5(1)(xxxi). The Explanation reads as under : " For the purposes of clause (xxxa), this clause, clause (xxxii) and clause (xxxiv), the term 'industrial undertaking' means an industrial undertaking engaged in the business of generation or distribution of electricity or any other form of power or in the constructi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... igh Court in Addl. CIT v. Farrukhabad Cold Storage (P.) Ltd. [1977] 107 ITR 816. In this case, the Division Bench held that the term processing Of goods " as used in section 2(7)(d) of the Finance Act need not be of such a nature as to result in the manufacture of goods. All that is required is that the goods must be adapted for a particular purpose. Both the words " manufacture " and " processing ..... X X X X Extracts X X X X X X X X Extracts X X X X
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