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TMI Blog1977 (9) TMI 42X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee in the assets forming part of the undertaking of the two firms were exempt from inclusion in the net wealth of the assessee for the two years respectively. The assessee claimed exemption with regard to a sum of Rs. 49,615 being his capital standing in the books of South India Star Tannery and Rs. 20,149 in the books of East India Goat Sheep Tannery in the asst. yr. 1974-75 and Rs. 27,985 as his capital in the books of South India Start Tannery in the asst. yr. 1975-76 as representing the value of his interest in the assets of the undertakings of the two firms other than the land building or any asset referred to in any other clause of sub-s. (1) of s. 5 of the WT Act. The ITO observed that on making enquiry it was revealed that the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e the two firms undertook in their undertakings of the business of tanning of skins. We reproduce the same below: First stage Lime water Chemical Water 13 days Second stage 1. Chawl Water 7 days Second stage 2. Chawl Water 7 days Third stage Kadukkai 2 days Fourth stage Oil 1 day Fifth stage Thana (Dena) 1 day . Dana drying 1 day Total 32 days 4. Having regard to the different process involved is tanning as given above we are of the view that the business of tanning of skins was certainly processing of goods and as such the undertaking of the two firms were industrial undertakings ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... raw skin cannot be said to involve processing. In fact the tanned skin can easily be taken as a different end product than a raw skin. in conclusion we held that the activities of the two firms constituted then as industrial undertakings. 7. However, the question as to how much was the value of the interest of the assessee in the assets, forming part of the industrial undertakings of the two firms which are exempt under cl. (xxxii) of s. 5(1) of the Act requires to be gone into. The capital of the assessee as standing in the books of the two firms cannot be taken as such as representing the value of the said interest of the assessee in the two firms. We would accordingly set aside the order of the AAC for the two years and send the matte ..... X X X X Extracts X X X X X X X X Extracts X X X X
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