Commissioner Of Income-Tax vs Sultan And Sons Rice Mill on 5 November, 2004
It must be construed liberally in the broad commercial sense from the common sense (CIT v. Orient Paper Mills Ltd. [1974] 94 ITR 73 (Cal)). The expression "manufacturing process" should be interpreted in its ordinary sense and should not be confined or restricted to the actual manufacturing alone. The processes which are intimately connected with actual manufacturing process will also be within the aforesaid expression. The Tribunal, as a last fact-finding authority has found that the workers employed for bringing the paddy bags from outside and keeping it in the factory can also be called "workers employed in the manufacturing process" as the manufacturing process cannot be carried on unless paddy bags are available represents the correct view of law and is in consonance with the plain meaning of the word implied under Section 80J(4)(iv) of the Act.