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TMI Blog1981 (6) TMI 49X X X X Extracts X X X X X X X X Extracts X X X X ..... IT Act, 1961. 2. The assessee is engaged in the business of purchase and sale of Chloride Powder. It was also under taking grinding work on behalf of M/s Podar Trading Co. Pvt. Ltd. The relief claimed by the assessee under s. 80J relates to the second activity. The work is done as job work by levying grinding charges. For obtaining relief under s. 80J(1) the work undertaken by the assessee must ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... occurred in s. 15C of the old Act also. The assessee in that case was engaged in the process of cutting rocks and boulders into chips of various sizes with the use of machinery. There also the Deptt. took the stand that no manufacturing or processing was involved. It was held by the Madras High Court, having regard to the meaning of the word 'manufacture' occurring in Dictionaries, that the proce ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 59(6A)-2. It related to the processing of shrimps and the relief claimed was under s. 80HH which also uses the expression 'manufactures or produces articles'. The Tribunal held that processing may not amount to manufacture, but it certainly amounts to production at least for income-tax purposes in the context in which that expression is used. The Tribunal has also observed that although by this p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mixture to certain process under pressure along with iron bars at the site. A new independent product known as 'pile' was being brought into existence. It was held by the High Court that the 'pile' prepared at the construction site by the special process can be said to be an article which was manufactured and the question was answered in favour of the assessee. But, in discussing the matter the fo ..... X X X X Extracts X X X X X X X X Extracts X X X X
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